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file a tax return, except (as relevant here) that a return shall
not be required of an individual who is not married, is not a
surviving spouse, is not a head-of-household, and for the taxable
year has gross income of less than the sum of the exemption
amount plus the basic standard deduction applicable to such
individual. Individual tax returns are due on or before the 15th
day of the fourth month following the close of the tax year. See
sec. 1.6072-1(a), Income Tax Regs.
The term "gross income" means "all income from whatever
source derived." Sec. 61. The exemption amounts applicable to
petitioner for the tax years 1993 and 1994 were $2,350 and
$2,450, respectively. See sec. 151(d). The standard deduction
amounts applicable to petitioner for tax years 1993 and 1994 were
$3,700 and $3,800, respectively. See sec. 63(c). Thus,
petitioner was required to file for 1993 and 1994 if his gross
income in those years exceeded $6,050 and $6,250, respectively.
Petitioner stipulated the fact that he had gross income in 1993
and 1994 of $28,440 and $14,896, respectively. Petitioner,
therefore, was required to file a return in the years at issue
since his gross income for those years clearly exceeded the
minimum statutory amounts for filing.
Petitioner claimed that he did not file returns for 1993 and
1994 because, based on his reading of the instructions
accompanying his tax return forms for the years in question, he
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