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On September 11, 2003, petitioner filed her Tax Court
petition2 in this case seeking review of the notice of deficiency
that was issued to her for 2002. At no time during the period
from her receipt of the April 4, 2003, 30-day letter through
September 11, 2003, when she filed her petition, did petitioner
request an Appeals Office conference.
On October 15, 2003, respondent filed his answer asserting
that his determinations in the notice of deficiency should be
sustained.
From July 2, 2003, through September 29, 2004, petitioner
provided substantial information and documentation to the
Internal Revenue Service supporting her entitlement to head of
household filing status and to her claimed exemptions and earned
income and child care credits.
Petitioner and her representatives advised respondent that
petitioner was married, but they maintained that in 2002
petitioner and her husband lived apart. Initially, petitioner’s
counsel communicated only with the Taxpayer Advocate’s Office and
an examiner in respondent’s Examination Division. Later, on
October 14, 2003, after petitioner filed her petition and
respondent prepared his answer, respondent’s counsel forwarded
the administrative file to the Appeals Office in Oklahoma City.
2 Though the Court filed the petition on Sept. 16, 2003, the
Sept. 11, 2003, date of the postmark on the cover in which the
petition was mailed is deemed to be the date of delivery. See
sec. 7502(a)(1).
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