Stephen W. Williams - Page 1

                                   114 T.C. No. 8                                     

                               UNITED STATES TAX COURT                                

                         STEPHEN W. WILLIAMS, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23179-97.                    Filed March 1, 2000.           

                    P mailed two Forms 1040, U.S. Individual Income                   
               Tax Return, for 1991 to the IRS.  The first Form 1040                  
               included a deduction for “Non Taxable Compensation”                    
               equal to P’s total income, and P failed to sign it.  P                 
               stipulated that this Form 1040 is not a valid return.                  
               In the second Form 1040, P reported taxes owed of                      
               $36,621.  P however attached a disclaimer statement to                 
               the second Form 1040 stating that he denied all tax                    
               liability and did not admit that the stated amount of                  
               tax was due.                                                           
                    Held:  P is liable for the deficiency.                            
                    Held, further, P’s second Form 1040 is not a valid                
               return; therefore, P is not liable for the accuracy-                   
               related penalty pursuant to sec. 6662(a), I.R.C.                       
                    Held, further, P is liable for the addition to tax                
               pursuant to sec. 6651(a)(1), I.R.C.                                    
                    Held, further, P is liable for a penalty under                    
               sec. 6673, I.R.C.                                                      

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