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income within the United States. Predictably, respondent did not
consider nor accept petitioner's filings for 1994 and 1995 as
income tax returns. For 1996, petitioner did not file anything
with respondent with respect to her income tax for that year.
The notice of deficiency followed in due course.3 In her
petition with this Court, petitioner's sole allegation is that
"Taxes were timely filed with Philadelphia IRS as I was
instructed by IRS to do. IRS should go by tax forms that they
originally accepted." After the petition was filed and the case
was assigned to one of respondent's Appeals officers, petitioner
submitted unsigned Forms 1040 for the years 1994 and 1996, in
which some of petitioner's income was listed. The 1994 Form 1040
showed an overpayment of $502, and the 1996 Form 1040 showed a
tax due of $1,091.4 The only apparent effects of the unsigned
returns submitted were respondent's concessions regarding
petitioner's filing status and her entitlement to itemized
deductions for 2 of the years at issue. See supra note 2.
Prior to trial, petitioner filed a Motion For Summary
3 The income adjustments in the notice of deficiency are
based on information returns filed by payers, some of which were
not included on the statements and declarations petitioner filed
with respondent.
4 In respondent's trial memorandum, as well as in a
posttrial memorandum, respondent refers to petitioner's
submission of an unsigned Form 1040 for the year 1995. Although
the unsigned Forms 1040 for the years 1994 and 1996 were offered
into evidence, no such Form 1040 was offered into evidence for
1995.
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