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Petitioner responded to the examination letter by mailing
various documents to respondent. After reviewing the documents,
respondent concluded that the information submitted by petitioner
was insufficient to verify the items under examination.
By letter dated April 6, 1999 (the proposed adjustment
letter), respondent proposed a deficiency of $4,215 in
petitioner’s 1998 Federal income tax. The proposed deficiency
was predicated on a change in petitioner’s filing status from
head of household to single, the disallowance of the three
dependency exemptions, and the partial disallowance of the earned
income credit. The proposed adjustment letter informed
petitioner that he had not submitted all of the documentation
that respondent had requested. The letter also listed each item
that respondent still required for verification.
Petitioner responded to the proposed adjustment letter by
mailing various documents to respondent. After reviewing the
documents, respondent concluded that they were insufficient to
verify the items under examination. By letter dated May 11, 1999
(the May 11th letter), respondent so informed petitioner.
Respondent also repeated his request for documentation
establishing that petitioner’s children lived with petitioner for
more than 6 months of 1998 and a record of funds that petitioner
spent in support of his children. Respondent also informed
petitioner that any further supporting documents or information
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