- 4 - an extension, respondent’s earliest period of limitations would have expired on October 16, 2004. On June 29, 2004, respondent issued a statutory notice of deficiency for 2000 and 2001 after it was evident that petitioner would not consent to extend the period of limitations for 2000. Respondent determined deficiencies in petitioner’s Federal income taxes of $7,852.28 for 2000 and $2,090.63 for 2001. The statutory notice of deficiency included adjustments2 to petitioner’s tax returns, because she failed to substantiate her cost of goods sold and business expenses. On October 18, 2004, petitioner filed Form 1040X, Amended U.S. Individual Income Tax Return, for year 2000, to claim a dependency exemption deduction for her daughter, a child tax credit, and head of household filing status. Petitioner did not sign the Form 1040X, and she did not include any documentation to support her claims. Around November of 2004, petitioner retained John C. Mullaney as her attorney to file a petition with the Court and to represent her in the appeals process within the IRS. On November 29, 2004, petitioner filed a petition with the Court. The petition alleges that “Revenue Agent issued Statutory Notice of deficiency because taxpayer refused to extend statute of 2The correct computation of petitioner’s self-employment adjusted gross income adjustments and self-employment taxes for 2000 and 2001 will be determined by the parties’ resolution of the issues of petitioner’s cost of goods sold and substantiation of business expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011