Stephen W. Williams - Page 4

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          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)          900                                 




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Last modified: May 25, 2011