James L. and Sherri R. Goertler - Page 3

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          deductions) for personal exemptions with respect to three                   
          children claimed as dependents (the children).                              
               By letter dated September 5, 2000, with which an examination           
          report was enclosed, a Branch Chief at respondent’s Ogden                   
          Customer Service Center notified petitioners that their 1998                
          return was under examination and requested documentation                    
          establishing the dependent status of the children. That request             
          apparently was occasioned by respondent’s discovery of a child              
          support order with respect to one of the children.3  In pertinent           
          part, the letter states as follows:                                         
                    Based upon our initial review of your return,                     
               we’ve prepared the enclosed examination report showing                 
               the proposed changes we will make to items on your                     
               return if we don’t receive any additional information                  
               from you.  * * *                                                       
                         *    *    *    *    *    *    *                              
                    If you do not agree with the proposed changes,                    
               please include the following information with your                     
               response:                                                              
                         *    *    *    *    *    *    *                              
                    We will review what you send us and contact you as                
               soon as possible.  Should you still disagree with our                  
               findings after we review your response and any                         
               additional information you provide, you have the right                 
               to file an administrative appeal * * * .  You first                    
               must have provided relevant information to the Contact                 
               Person named on this letter before your case can be                    
               considered by Appeals.                                                 


               3  As listed on the 1998 return, the surname of the child in           
          question does not match that of petitioners.  The surname of the            
          other two children as listed on the 1998 return matches that of             
          petitioners.                                                                




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