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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
“unnecessary”.
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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Last modified: May 25, 2011