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of law. Accordingly, we shall grant respondent’s motion for
summary judgment.
Background
On or about April 27, 1998, Glen A. Blair (petitioner) and
his wife, Kay Blair, submitted to respondent a joint Form 1040A,
U.S. Individual Income Tax Return, for 1997. Petitioner entered
zeros on every line of the income sections of the Form 1040A,
reported no tax due, and claimed a refund in the amount of
$5,158.39 equal to the amount of Federal income tax withheld from
his wages. A Form W-2, Wage and Tax Statement, attached to the
Form 1040A indicates that Union Oil Company of California paid
petitioner wages in the amount of $45,183.73 during 1997.
On June 16, 2000, respondent issued a notice of deficiency
to petitioner determining a deficiency of $8,263 in his Federal
income tax for 1997 and an accuracy-related penalty under section
6662(a) in the amount of $620.32. The deficiency was based on
respondent’s determination that petitioner failed to report the
wage income reported to respondent by Union Oil Co.
On July 4, 2000, petitioner wrote a letter to the Director
of respondent’s Service Center in Ogden, Utah, acknowledging
receipt of the notice of deficiency for 1997, but challenging the
Director’s authority to issue such notices. Although petitioner
knew that he had the right to contest respondent’s deficiency
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