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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.
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