- 7 -
Under this formula, then, the deficiency is determined by
comparing the tax imposed to: (1) The tax shown on the return;
(2) amounts previously assessed as a deficiency; and (3) any
rebates made. We consider each of these elements in turn.
Tax Shown on the Return
When petitioner filed his 1997 tax return, he did not show
an amount of tax due. The parties do not dispute that petitioner
made a valid election, pursuant to section 6014(a), to have
respondent compute his tax liability.4 Respondent’s computation
of tax under section 6014 “shall be considered as having been
made by the taxpayer and the tax so computed considered as shown
by the taxpayer upon his return.” Sec. 6211(b)(3); see sec.
301.6211-1(c), Proced. & Admin. Regs.
On or about May 25, 1998, respondent computed petitioner’s
1997 tax liability as being $7,219. Accordingly, for purposes of
section 6211(a)(1)(A), the tax shown on the return is $7,219.
4 Sec. 6014(a) authorizes the Commissioner to compute the
tax liability of a taxpayer who satisfies the criteria, inter
alia, of having gross income that is less than $10,000 and that
includes no income other than wages, dividends, or interest.
Sec. 6014(b) directs the Commissioner to prescribe regulations to
extend this authority to cases where the taxpayer has gross
income of $10,000 or more. Pursuant to this directive, sec.
1.6014-2, Income Tax Regs., permits a taxpayer to make a sec.
6014(a) election without regard to the amount or nature of the
taxpayer’s gross income.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011