Willie R. Davidson - Page 3




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               As explained in detail below, there is no genuine issue as             
          to any material fact, and a decision may be rendered as a matter            
          of law.  Accordingly, we shall grant respondent’s motion for                
          summary judgment.                                                           
          Background                                                                  
               A.  Petitioner’s Form 1040 for 1997                                    
               On or about April 23, 1998, Willie R. Davidson (petitioner)            
          and his wife, Dawn F. Davidson, submitted to respondent a Form              
          1040, U.S. Individual Income Tax Return, for the taxable year               
          1997.  On the Form 1040, the Davidsons listed their filing status           
          as “married filing joint return” and described their occupations            
          as “Tel Com. Employee”.                                                     
               The Davidsons entered zeros on applicable lines of the                 
          income portion of their Form 1040, specifically including line 7            
          for wages, line 22 for total income, and lines 32 and 33 for                
          adjusted gross income.  The Davidsons also entered a zero on line           
          53 for total tax.                                                           
               The Davidsons attached to their Form 1040 two Forms W-2,               
          Wage and Tax Statement, issued to them by Sprint/Central                    
          Telephone-Nevada, and a Form 1099-R, Distributions from Pensions,           
          Annuities, Retirement or Profit Sharing Plans, IRAs, Insurance              
          Contracts, etc., issued to petitioner by Northern Trust Co.  The            
          Form W-2 issued to petitioner discloses that petitioner was paid            
          wages in the amount of $48,701.01 and that there was no                     






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