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and worked for Faulkner Hospital in Jamaica Plain and the Hebrew
Rehabilitation Center for the Aged in Roslindale.
Respondent’s Andover, Massachusetts, Service Center received
petitioners’ 1995 Federal income tax return, Form 1040, on
November 20, 1996, together with Forms W-2. On line 7 of the
Form 1040, petitioners reported wages of $78,613; and on line 22,
total income of $78,613. They claimed total adjustments to
income on line 30 of $78,613 and adjusted gross income on line 31
of zero. Thereafter, zero amounts were reported on line 37--
taxable income, and line 54--total tax. Petitioners requested a
refund of $8,942, an amount representing their total Federal
income tax withholding. The return did not include Schedules C,
D, and E. Attached to the Form 1040 was a three-page "Affidavit
and Statement" submitted by petitioners which set forth various
tax protester arguments, rejected by this and other courts, in
support of their claim that they owe no income tax. Petitioners
filed their return claiming married filing jointly status and two
exemptions.
In the notice of deficiency dated April 18, 1997, respondent
determined that petitioners failed to include $10,300 of taxable
distributions in their gross income for 1995. Respondent
computed the deficiency as follows:
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