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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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Last modified: May 25, 2011