Dennis J. Lawless - Page 8

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               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.                                                    

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