Kristin J. Calitri - Page 5

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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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