- 3 -
reported. Petitioners left the return blank in all other
respects; they claimed no refund of tax withheld from the wages
of $65,128 shown on Form W-2 and did not attach Form W-2 to the
return.
On April 24, 1996, respondent mailed a statutory notice of
deficiency to petitioners, determining that petitioners had
income of $65,128 from wages, and $20 from interest that
respondent later conceded, applying the personal exemption and
standard deduction amounts to arrive at taxable income, giving
petitioners credit for the tax withheld from petitioner's wages,
computing their tax liability by affording them joint filing
status, and showing a balance due or underpayment of $5,019 and
the above-described additions.
On July 22, 1996, petitioners timely filed their petition
with this Court, disputing the unpaid portion of the deficiency
and the additions on the ground that “We do not believe we owe
the extra amount due above for this tax year”. On October 23,
1996, petitioner sent an Internal Revenue Service (IRS) Appeals
officer a letter containing three single-spaced pages of text
that petitioner asked to have treated as “an integral part” of
petitioners' return. This letter explains that petitioners filed
the return in order to avoid criminal liability as nonfilers; it
sets forth a series of canned arguments, accompanied by numerous
citations, that petitioners may have regarded as fresh and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011