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insufficient to verify the items under examination.
In response to the documents provided by petitioner on April
22, 2001, a second letter was sent to petitioner advising him
that additional information would be required. Respondent
enclosed with the letter a Form 866-A, Explanation of Items, and
requested additional information. Respondent indicated that
petitioner was considered a foster parent because he was not
identified as the father on the two birth records he provided.4
As such, respondent specifically requested, in part, documents to
verify that the two children lived with petitioner for the entire
2000 taxable year and that they were placed with petitioner by an
authorized agency.
In response to respondent’s second letter, petitioner
provided respondent with a handwritten document which stated that
petitioner was the “foster father” to the two children who
resided in the same household as their mother and petitioner.
By a notice of deficiency dated September 18, 2001,
respondent determined a deficiency in petitioner’s Federal income
tax for 2000 in the amount of $4,328. The deficiency was
attributable to the adjustments proposed in respondent’s April 6,
2001, letter; i.e., change in petitioner’s filing status from
head of household to single (with a concomitant change in the
4 During the administrative proceeding, petitioner had also
indicated to respondent that he was in fact the foster father to
the two children.
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