Said Mahmoud Karara - Page 11




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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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