Robert D. Aronfeld - Page 5




                                        - 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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