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perjury * * *, I can only swear to having “zero” income
* * *.
In addition to the foregoing contentions and arguments of
petitioner that appeared in the two-page document that he
attached to each of the Forms 1040A for 1994 and 1996 that he
prepared, petitioner advanced additional contentions and argu-
ments in that document, all of which the Court finds to be
groundless and frivolous.
At the February 12, 2001 Appeals Office hearing, petitioner
informed the Appeals Officer that he had filed returns for each
of the years 1994 and 1996 and that he had received a notice from
respondent in which respondent indicated that respondent consid-
ered each of those returns to be frivolous.
At the February 12, 2001 Appeals Office hearing, the Appeals
Officer attempted to discuss with petitioner the amount of tax
that he owed for each of the years 1994 and 1996 and the proper
way to prepare Form 1040 for each of those years. Petitioner did
not provide the Appeals Officer with a return for each of the
years 1994 and 1996, in which he reported his wage and any other
income and claimed deductions or a filing status different from
that shown in the substitute for return that respondent prepared
for each of those years. If he had, the Appeals Officer would
have sent such returns and any other information that petitioner
provided to her to respondent’s examination division for review
in order to determine whether petitioner’s tax liability for each
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