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preparer, executed Form 8453 (1999), U.S. Individual Income Tax
Declaration for an IRS e-file Return, on February 4, 2000. The
address listed on the Form 8453 was the Stilwell address.
Petitioner’s return for 1999, which was filed on a head-of-
household basis, reported zero income tax and claimed a refund in
the amount of $4,231. The latter amount consisted of withholding
in the amount of $481 and an earned income credit in the amount
of $3,750. Respondent never issued a refund check but rather
“froze” petitioner’s account.
In March 2000, respondent commenced an examination of
petitioner’s 1999 return. The examination focused on filing
status, dependency exemption deductions, and the earned income
credit.
On or about September 1, 2000, respondent issued a 30-day
letter proposing a deficiency in petitioner’s Federal income tax
for 1999. The 30-day letter stated, in part, as follows:
Thank you for your replies dated April 4 and May 24,
2000. To follow is a list of what we received:
* * * These documents do not allow us to establish
that you meet the requirements for these issues
involved. * * *
On December 6, 2000, respondent sent a notice of deficiency
to petitioner. In the notice, respondent determined a deficiency
in petitioner’s Federal income tax for the taxable year 1999 in
the amount of $4,714. The deficiency was attributable
principally to the disallowance of the earned income credit
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