Casey A. Roginiel - Page 3




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          5, Your Appeal Rights and How To Prepare a Protest If You Don’t             
          Agree.                                                                      
               Petitioner did not request an Appeals Office hearing.                  
               On August 6, 2000, petitioner responded to respondent’s July           
          24, 2000, letter by providing a copy of petitioner’s decree of              
          dissolution of marriage (decree).  The decree designated                    
          petitioner as the primary residential parent for both children.             
               In response to petitioner’s August 6, 2000, submission,                
          respondent sent petitioner Form 886-A, Explanation of Items,                
          which indicated that additional information was required by                 
          respondent.  Respondent specifically stated that acceptable forms           
          of supporting documentation to verify the children’s residency              
          would include “SCHOOL AND/OR MEDICAL RECORDS LISTING YOUR NAME AS           
          PARENT OR GUARDIAN, THE CHILD’S NAME, THE ADDRESS OF RECORD DATED           
          JANUARY THROUGH DECEMBER OF THE TAX YEAR.”  Acceptable forms of             
          supporting documentation to verify support would include                    
          cancelled checks or receipts for rent/mortgage and utilities.               
          The letter also stated that “IF YOU ARE ABLE TO FURNISH THE                 
          REQUIRED DOCUMENTATION WITHIN 90 DAYS, WE WILL BE ABLE TO                   
          RECONSIDER OUR CURRENT DETERMINATION.”                                      
               On December 7, 2000, respondent mailed to petitioner a                 
          notice of deficiency in the amount of $4,324 for the taxable year           
          1999.  The notice of deficiency reflected the same adjustments as           
          determined in respondent’s 30-day letter.                                   






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