Ronald A. Horton - Page 4

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         documents supported petitioner’s position that his daughter                  
         resided with him in 2002 and that he provided over half of her               
         total support for the year.  The parties reached a settlement                
         regarding the 2002 taxable year on September 30, 2004.  The                  
         parties agreed that petitioner was entitled to the claimed filing            
         status, credit, and deduction for the 2002 taxable year.                     
              On April 5, 2004, petitioner received a proposed notice of              
         deficiency from respondent’s examiner, Jan Sinclair (Ms.                     
         Sinclair), regarding the 2003 taxable year.  Respondent proposed             
         to disallow, for 2003, the same items as those at issue for the              
         2002 taxable year.  On May 3, 2004, petitioner sent a letter to              
         Ms. Sinclair asking her to use petitioner’s submissions for the              
         2002 taxable year to settle the 2003 taxable year.  Petitioner               
         asserted that once respondent had agreed to petitioner’s status              
         as head-of-household in 2002, the 2003 examination would be                  
              On June 14, 2004, respondent issued a notice of deficiency              
         to petitioner with respect to the 2003 taxable year.  On                     
         September 7, 2004, shortly before the parties reached a final                
         settlement regarding the 2002 taxable year, petitioner sent a                
         letter to Ms. Fu that stated in part:                                        
                   I don’t know if you can help us or not, but I am                   
              enclosing a copy of the very same type of notice for Mr.                
              Horton’s tax year 2003.  This was brought about, of course,             
              by the very same problem that we have finally brought to                
              resolution for 2002 now in 2004.                                        

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