- 4 - of wages of $20,500, taxable interest income of $14, a capital loss of ($2,986), and rents and partnership income of $133,324. Petitioner reported a total tax of $41,586 and an amount owed of $36,621. Petitioner, this time, did not strike or change any language on the form. Instead, beside the amount owed reported on line 64, petitioner placed an asterisk. At the bottom of the page, petitioner stated that the asterisk denoted “The admitted liability is zero. See attached Disclaimer Statement.” The attached disclaimer statement (the disclaimer) read in part: The above named taxpayer respectfully declines to volunteer concerning assessment and payment of any tax balance due on the return or any redetermination of said tax. Be it known that the above said taxpayer, therefore, denies tax liability and does not admit that the stated amount of tax on return is due and collectable. * * * Petitioner signed the disclaimer 1040. Except for the altered 1040 and the disclaimer 1040, petitioner did not mail to or file with the IRS any other Forms 1040 for 1991. During 1991, petitioner received income and incurred losses as follows: Wages from Williams P.C. $20,500 Interest from Vista Properties 14 (Vista) Interest from Charles Schwab 3 Net short term capital loss (2,986) Rents from Williams P.C. 29,000 Nonpassive loss from Vista (1,637) Nonpassive income from Williams P.C. 105,961 Rents from Summit Outdoor Advertising (Summit) 900Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011