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The enclosed Form 886-A (Explanation of Items) stated that
the claimed refund was “Frozen”.
Petitioner failed to respond to the May 16, 2003, letter.
On July 18, 2003, respondent issued the notice of deficiency
on which the instant case is based. The notice of deficiency
explanations are as follows:
Earned Income Credit
Per Return: $2890.00
Per Exam: $0.00
Per Adjustment: ($2,890.00)
Since you did not establish that you were entitled to
the earned income credit, we disallowed it.
Exemptions
Per Return: 6
Per Exam: 1
Per Adjustment: 5
Since you did not establish that you are entitled to
the exemptions(s), it/they is/are being disallowed.
Petitioner first consulted with Jeffrey D. Moffatt
(hereinafter sometimes referred to as Moffatt), petitioner’s
counsel in the instant case, on July 26, 2003. Petitioner
retained Moffatt on July 27, 2003.
On September 22, 2003, Moffatt filed a timely petition on
petitioner’s behalf. Paragraph 4 of this petition is as follows:
4. The determination of the tax set forth in the
said notice of deficiency (or liability) is based upon
the following errors:
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Last modified: May 25, 2011