- 4 - that petitioner wished respondent to consider should be received within 15 days of the date of the May 11th letter. By a notice of deficiency dated May 28, 1999, respondent determined a deficiency of $4,196 in petitioner’s 1998 Federal income tax. Petitioner hired counsel to represent him in June 1999. The petition was filed August 9, 1999. Respondent’s answer was filed October 12, 1999. On November 3, 1999, respondent assigned the case to an Appeals officer. On November 18, 1999, the Appeals officer spoke with petitioner’s counsel about settling the dispute. The following day, the Appeals officer mailed a letter to petitioner’s counsel proposing that respondent would concede the earned income credit issue if petitioner conceded the dependency deductions and head of household filing status issues. On January 11, 2000, the Appeals officer received a letter from petitioner’s counsel suggesting that she agree to concede all three issues. Attached to the letter were documents concerning petitioner’s public assistance, dependency deductions, and filing status. After reviewing the letter and documents, the Appeals officer did not alter her settlement position. In February 2000, the Appeals officer forwarded the case to respondent’s District Counsel office for trial preparation. After reviewing the case, the District Counsel office offered to settle the dispute with petitioner on the same terms that hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011