Rajesh Prabhakar - Page 2

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          September 26, 2005, this Court entered a decision, pursuant to a            
          signed decision document, in favor of petitioner.                           
                                     Background                                       
               Petitioner timely filed his 2002 Federal income tax return.            
          On this return, petitioner reported wages of $56,225, interest              
          income of $217, tax-exempt interest income of $457, a capital               
          loss of $3,000, and a section 222 qualified tuition and related             
          expenses deduction (tuition expense) of $3,000.  In addition, he            
          requested a refund of $1,287.                                               
               In a 30-day letter dated May 3, 2004, respondent asserted              
          that petitioner was liable for an income tax deficiency and                 
          accuracy-related penalty relating to 2002.  Respondent explained            
          that “Since there was no breakdown on * * * [petitioner’s] tax              
          return, we could not locate specific amounts of interest,                   
          dividends and/or capital gains distributions to match the amounts           
          * * * [petitioner’s] payers reported to us.”  Respondent also               
          disallowed petitioner’s tuition expense.                                    
               Respondent, in the 30-day letter, stated that if petitioner            
          disagreed with the proposed changes, petitioner should send                 
          respondent a statement “explaining each change you disagree with            
          and why you disagree [and include] any supporting documents you             

               1(...continued)                                                        
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  






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