- 3 -
On January 2, 2004, respondent notified petitioner that the
information that he had provided with respect to his 2001 tax
return did not support a change to the proposed adjustments. The
correspondence also informed petitioner that “You have had 90
days to file a petition with the United States Tax Court. If you
did not file a petition and still disagree with our
determination, you may, after paying the additional tax due, file
an amended return or a claim for refund.”
On February 9, 2004, respondent assessed the additional tax
against petitioner as a result of the adjustments and the
disallowance of the earned income credit. Petitioner neither
paid the additional tax assessed for 2001 nor filed an amended
return or claim for refund. On March 29, 2004, petitioner sent a
letter to this Court requesting the necessary documents to file a
petition for redetermination of a deficiency for the 2002 taxable
year.3 This Court treated the letter as a petition and assigned
it docket No. 5812-04S. On April 5, 2004, this Court issued an
order directing petitioner to file a proper amended petition in
docket No. 5812-04S. On May 10, 2004, petitioner filed the
amended petition and disputed the deficiency respondent asserted
for the 2001 taxable year.
3 Although petitioner’s Mar. 29, 2004, letter refers to his
2002 taxable year, respondent did not send petitioner a notice of
deficiency regarding his 2002 taxable year. Petitioner’s
reference to 2002 appears to be an error; in fact, the amended
petition disputes the deficiency for petitioner’s 2001 tax year.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011