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of law. Accordingly, we shall grant respondent’s motion for
summary judgment.
Background
On July 8, 1998, petitioners submitted to respondent a joint
Form 1040, U.S. Individual Income Tax Return, for 1997.
Petitioners entered zeros on every line of the income section of
the Form 1040, specifically including line 7 for wages, line 22
for total income, and line 32 for adjusted gross income.
On October 15, 1999, respondent issued a joint notice of
deficiency to petitioners determining a deficiency of $3,838.20
in their Federal income tax for 1997, an addition to tax under
section 6651(a) of $249.90, and an accuracy-related penalty of
$333.21. The deficiency was based principally on respondent’s
determination that petitioners failed to report wage income and a
taxable distribution from a retirement account.
On January 11, 2000, petitioners wrote a letter to
respondent acknowledging receipt of the notice of deficiency
dated October 15, 1999, and challenging its validity.
Petitioners did not file a petition for redetermination with the
Court challenging the notice of deficiency.
On March 20, 2000, respondent entered assessments against
petitioners for the deficiency, addition to tax, and accuracy-
related penalty determined in the notice of deficiency described
above. Respondent also entered an assessment against petitioners
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