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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011