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Pursuant to section 1(c) for 1996 and section 1(d) for 1997,
as well as the tax tables mandated by section 3(a), (c),
petitioner’s tax liabilities for the years in issue are as
follows:
1996 1997
$2,366 $2,546
In view of the fact that petitioner did not file income tax
returns for the years in issue, petitioner’s tax liabilities for
those years constitute deficiencies in income taxes. See sec.
6211(a). Accordingly, we hold that petitioner is liable for the
deficiencies in income taxes as determined by respondent in the
notice of deficiency.3
B. Addition to Tax For Failure To File
As applicable to petitioner, section 6012(a)(1)(A)(i)
requires that an income tax return be filed by every individual
who has gross income equal to, or greater than, the sum of the
standard deduction and one personal exemption. For an individual
who is a calendar-year taxpayer, the return is due on or before
the 15th day of April following the close of the taxable year.
3 Because petitioner was married in 1997, see sec.
7703(a)(1), respondent should have utilized the tax table
applicable to married individuals filing separately and the
standard deduction applicable to that filing status. As a
consequence, respondent’s deficiency determination for 1997 was
understated. However, respondent has not asserted any claim for
an increased deficiency. See sec. 6214(a). Accordingly, we lack
jurisdiction to redetermine the correct amount of the deficiency.
See id.
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