Thu Cuc Thi Huynh - Page 4




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          and (2) disallow the two dependency exemptions and the earned               
          income credit.  Concurrently, respondent requested specific                 
          information and documentation from petitioner to substantiate the           
          filing status, dependency exemptions, and earned income credit as           
          claimed on her return.                                                      
               Petitioner either failed to respond or failed to respond               
          adequately to respondent’s request.  Accordingly, in September              
          1999, respondent determined a deficiency in petitioner’s income             
          tax for 1998.  The deficiency was attributable to the adjustments           
          proposed in respondent’s April 23, 1999, letter.                            
               In December 1999, petitioner commenced a case in this Court            
          by filing a petition for redetermination.  See sec. 6213(a).                
          Petitioner’s case was assigned docket No. 18517-99S.  In her                
          petition, petitioner alleged that she provided her son’s “entire            
          support”.                                                                   
               Petitioner’s case was considered by respondent’s Appeals               
          Office at the Philadelphia Service Center.  In due course, the              
          case was settled by respondent’s concession that petitioner was             
          entitled to the refund of tax as claimed on her return.  A                  
          stipulation to that effect was filed by the parties on October 2,           
          2000.  On the following day, the Court entered decision “pursuant           
          to the stipulation of the parties”.                                         










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