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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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