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C. Petitioner’s Tax Return for 1999
In March 2000, petitioner filed a U.S. Individual Income Tax
Return, Form 1040, for the taxable year 1999. On her return,
petitioner claimed: (1) Head of household filing status; (2) the
standard deduction for that filing status; (3) a dependency
exemption for Hai (but not for Mrs. Nguyen); and (4) an earned
income credit based on her son as a “qualifying child”.
Petitioner also claimed a refund of tax in the amount of $2,177.
Petitioner’s 1999 return was selected for examination. By
letter dated April 21, 2000, respondent sent petitioner an
examination report in which respondent proposed to: (1) Change
petitioner’s filing status from head of household to single (and
allow only the standard deduction for the latter filing status);
and (2) disallow the dependency exemption and the earned income
credit. In the letter, respondent also advised petitioner that
if she disagreed with the proposed changes, respondent would
consider whatever information and documentation that she might
care to submit. In this regard, respondent provided petitioner
with Form 886-H, Supporting Documents, that outlined the type of
information and documentation relevant to resolving issues
related to filing status, dependency exemptions, and the earned
income credit. Finally, respondent advised petitioner of her
right to appeal administratively the proposed changes and
enclosed with the letter a copy of Publication 5, Your Appeal
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