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taxable year 2000. On his return, petitioner listed his filing
status as head of household, and he claimed dependency exemptions
for two children (Lilly Phan and Anna Phan), the earned income
credit, and the child tax credit. Petitioner also claimed a
refund of tax in the amount of $4,098.
Petitioner’s 2000 return was selected for examination. By
letter dated April 6, 2001 (the examination letter), respondent
proposed to: (1) Change petitioner’s filing status from head of
household to single (and allow only the standard deduction for
the latter filing status); and (2) disallow the two dependency
exemptions, the earned income credit, and the child tax credit.
Concurrently, respondent requested specific information and
documentation from petitioner to substantiate the filing status,
dependency exemptions, earned income credit, and child tax credit
as claimed on his return.
On April 22, 2001, petitioner responded to the examination
letter by mailing various documents to respondent. This material
included a birth registration notice (not a birth certificate)
for Lilly Phan, a birth certificate for Anna Phan, a Social
Security card for each child, a purported lease, and a letter
from Lamont Elementary School regarding Lilly Phan’s enrollment.
Neither of the birth records for the two children identified
petitioner as their father. After reviewing this material,
respondent concluded that the information submitted was
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