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At the time the Petition for Lien or Levy Action Under
Section 6320(c) or 6330(d) was filed, petitioner resided in Las
Vegas, Nevada.
On April 15, 1997, petitioner filed his 1996 Form 1040EZ,
Income Tax Return for Single and Joint Filers With No Dependents.
Petitioner’s 1996 return listed his address as 5125 Gray Lane,
Apartment C, Las Vegas, Nevada, 89119 (Gray Lane address). On
his 1996 return, petitioner reported wages and salaries of zero.
Petitioner also reported that his adjusted gross income and
taxable income on his 1996 return was zero. In a two-page
document attached to his 1996 return, petitioner stated in part:
It should also be noted that I had “zero” income
according to the Supreme Court’s definition of income
(See Note #1), since in Merchant’s Loan & Trust Co v.
Smietanka, 225 U.S. 509, (at pages 518 & 519) that
Court held that “The word (income) must be given the
same meaning in all of the Income Tax Acts of Congress
that was given to it in the Corporation Excise Tax Act
(of 1909).” Therefore, since I had no earnings in 1996
that would have been taxable under the Corporation
Excise Tax Act of 1909 as “income,” I can only swear to
having “zero” income in 1996.* * *
On April 15, 1998, petitioner filed his 1997 Form 1040EZ.
Petitioner’s 1997 return reflected his Gray Lane address. Again,
petitioner reported wages and salaries of zero on his 1997
return. Petitioner also reported that his 1997 adjusted gross
income and taxable income was zero. Petitioner attached a two-
page document to his 1997 return which was essentially identical
to the two-page document attached to his 1996 return.
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Last modified: May 25, 2011