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verify rental and utility payments. Finally, respondent again
advised petitioner of her right to appeal administratively the
proposed changes and enclosed another copy of Publication 5.
Petitioner did not respond to respondent’s June 23, 2000,
letter, nor did petitioner administratively appeal the proposed
changes to her 1999 return. Accordingly, on October 6, 2000,
respondent sent petitioner a notice of deficiency.
The deficiency as determined by respondent was in the amount
of $2,347 and was based on the same adjustments as proposed in
respondent’s April 21, 2000, letter; i.e., change in petitioner’s
filing status from head of household to single (with a
concomitant change in the amount of the standard deduction) and
disallowance of the dependency exemption and the earned income
credit in respect of petitioner’s son.
On October 23, 2000, petitioner retained her present
counsel. Shortly thereafter, on October 29, 2000, petitioner’s
counsel sent a letter to respondent requesting that the notice of
deficiency be rescinded based on respondent’s concession in
docket No. 18517-99S (the case involving the 1998 year).
Petitioner’s counsel imposed a deadline of November 23, 2000, for
respondent to agree to a rescission. Petitioner’s counsel did
not provide any of the information or documentation that
respondent had previously requested in respondent’s letters dated
April 21, 2000, and June 23, 2000, to petitioner.
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