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sent petitioner a so-called 30-day letter dated September 13,
2000, proposing adjustments to petitioner’s 1999 tax return.
In a letter dated September 27, 2000, petitioner sent
respondent copies of several utility bills, Social Security cards
for himself and his two children, and two letters from a school
stating that the children resided with petitioner.
Respondent responded by issuing a notice of deficiency dated
December 11, 2000, stating in part:
We have received your correspondence on October
11, 2002, in regard to the examination of your 1999 tax
return.
After reviewing the correspondence you submitted,
we have determined that additional information is
necessary to resolve the issues. Please see the
enclosed explanations listing the adjusted items. In
order for us to reconsider the proposed adjustment, you
must submit the documentation explained on the
attachments.
Petitioner did not submit any of the requested documentation.
Without the benefit of additional information from petitioner,
respondent determined a deficiency in petitioner’s Federal income
tax of $4,354 for the 1999 taxable year.
Petitioner filed a petition on March 5, 2001, and an amended
petition on May 4, 2001. At the time of filing the petition,
petitioner resided in Johnstown, Pennsylvania.
From June 2001 to February 2002, respondent’s Pittsburgh
Appeals Office sent petitioner six letters seeking information
regarding his case. Respondent’s counsel also sent petitioner
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Last modified: May 25, 2011