- 4 -
For 1997, petitioner filed what respondent referred to as a
zero return for the reason that petitioner listed on the IRS Form
1040 a zero amount for income, adjustments to income, and taxes
due but claimed an overpayment of $29.70 in taxes. Petitioner
did, however, attach to his return copies of various information
returns of amounts paid to him by various payers that included
Social Security retirement benefits, nonemployee compensation,
and IRS Forms W-2 from several employers. The 1997 return also
included a two-page typewritten statement by petitioner extolling
the reasons why he was not liable for Federal income taxes.
Those reasons can best be described as tax protester arguments.4
In the notices of deficiency, respondent made certain
adjustments on petitioner's 1995 tax return recategorizing
petitioner's reported income and disallowed certain itemized
deductions and certain trade or business expenses, including a
net operating loss carryover deduction, all for lack of
substantiation. The adjustments for 1996 also involved a
recategorizing of income and the disallowance of various trade or
business expenses.
It does not appear that petitioner was engaged in any trade
or business activity during 1997. Respondent determined the
4 Although the record is not clear, it appears that
respondent did not accept petitioner's purported return as a
return, and, therefore, it was not filed.
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