- 7 -
(argument that wages and salaries are not income is “totally
lacking in merit”); Hayward v. Day, 619 F.2d 716, 717 (8th Cir.
1980); Rowlee v. Commissioner, supra at 1120; Grimes v.
Commissioner, 82 T.C. 235 (1984); Liddane v. Commissioner, supra;
Cocozza v. Commissioner, supra; Talmage v. Commissioner, supra.
We need not exhaustively review and respond to petitioner's
baseless and misguided contentions. Crain v. Commissioner, 737
F.2d 1417 (5th Cir. 1984).
2. Accuracy-Related Penalty Under Section 6662(a)
The 20-percent accuracy-related penalty under section
6662(a) can be imposed only if a valid tax return is filed. Sec.
6664(b). In Williams v. Commissioner, 114 T.C. 136 (2000), this
Court held that a section 6662 penalty can be imposed only if a
taxpayer files a valid (although erroneous) return. Because the
taxpayer in Williams had filed only invalid returns (first an
unsigned return, and second a signed amended return with an
improper disclaimer), no section 6662(a) accuracy-related penalty
could be imposed.
Like the taxpayer in Williams, petitioner filed an unsigned
Form 1040 tax return showing zero tax owing. An unsigned tax
return is of no effect. A Form 1040 that is not duly signed and
verified under penalties of perjury does not constitute a valid
Federal income tax return. Lucas v. Pilliod Lumber Co., 281 U.S.
245 (1930); Elliott v. Commissioner, 113 T.C. 125, 128 (1999);
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