Charles G. and Daphne C. M. Hall - Page 3




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          Background                                                                  
               A.  Petitioners’ Form 1040 for 1998                                    
               On or about August 19, 1999, petitioners submitted to                  
          respondent a joint Form 1040, U.S. Individual Income Tax Return,            
          for the taxable year 1998.  On the Form 1040, petitioners listed            
          their filing status as “Married filing joint return”.                       
               Petitioners 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 33 and 34 for adjusted           
          gross income.  Petitioners also entered a zero on line 56 for               
          total tax.  Petitioners claimed an overpayment of $2,333 related            
          to Federal income tax withholding.  Petitioners attached to their           
          Form 1040 four Forms W-2, Wage and Tax Statement, issued to                 
          petitioners by various employers.                                           
               B.  Respondent’s Deficiency Notice and Petitioners’ Response           
               On May 26, 2000, respondent issued to petitioners a joint              
          notice of deficiency.  In the notice, respondent determined a               
          deficiency of $4,736 in petitioners’ Federal income tax for 1998            
          and an accuracy-related penalty under section 6662(a) for                   
          negligence or disregard of rules or regulations of $480.53.  The            
          deficiency was based principally on respondent’s determination              
          that petitioners failed to report the wage income as reported to            
          respondent by third-party payors on Forms W-2.                              








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