Paula M. Olsen - Page 4

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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              

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