Shade D. Coleman III and Maria M. Coleman - Page 3

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          of law.  Accordingly, we shall grant respondent’s motion for                
          summary judgment.                                                           
               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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