-3-
square-foot home on the lot and improved the land. He resided in
the house. On September 22, 1994, petitioner and Ploe sold the
3545 Sierra Lane property for a net sale price of $208,387.31.
On October 14, 1994, petitioner and Ploe bought other land
for $36,292.15.
2. Petitioner's Dividend Income
Petitioner received dividends of $796 from Kemper Clearing
Corp. in 1994.
3. Petitioner's Form 1040 for 1994
Petitioner sent to respondent an unsigned U.S. Individual
Income Tax Return, Form 1040, for 1994. On it, he placed his
IRS-generated return address label and left blank the lines for
income, adjustments, tax, credits, and other taxes. He attached
to it a document stating that he was a nonresident alien residing
in the United States and that he was "no longer going to
voluntarily comply to your private tax collection filing system *
* *". Petitioner did not send any other Form 1040 to respondent
for 1994. Respondent prepared a substitute return for petitioner
on April 15, 1995.
B. Notice of Deficiency
Respondent sent a notice of deficiency to petitioner on
October 17, 1997. In it, respondent determined that petitioner
had a capital gain of $208,387 on the sale of his personal
residence and dividend income of $796 from Kemper Clearing Corp.
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