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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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