Daniel Joseph White - Page 9




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               $14,686.00 on line 57 * * *.  It could be Form W-2 (for wage           
               income), Form W-2G (for gambling winnings), or Form 1099-R             
               (for pension income).  * * *                                           
               Your return doesn’t show your signature(s).  Please sign               
               the declaration below and note the additional requirements             
               that may apply to you:                                                 
               1.  If this is a joint return, both husband and wife must              
               sign the declaration.                                                  
          Petitioner concedes that the return lacked Mrs. White’s                     
          signature, but he asserts that he signed the return on April 5,             
          1998.  Respondent has failed to explain this letter and his                 
          position that no return was filed until December 1, 2000.  Based            
          on this record we find that the return received by respondent as            
          acknowledged in the letter dated May 30, 2000, contained                    
          petitioner’s signature.  Moreover, petitioner’s failure to attach           
          a Form W-2 to the return does not render the return insufficient.           
          Blount v. Commissioner, supra at 387.                                       
               Petitioner signed a copy of the original return a second               
          time on September 30, 2000, and a third time on November 28,                
          2000.  He testified that he re-signed the return either at the              
          request of respondent’s revenue agent who had been conducting the           
          audit of petitioner’s prior returns, or in response to a letter             
          sent by respondent informing petitioner that the return required            
          an original signature.  We note that the revenue officer                    
          acknowledged receipt of petitioner’s 1992 and 1993 returns by               
          letter dated March 19, 1997; however, this letter does not                  
          acknowledge petitioner’s 1997 return.  Petitioner appears to have           





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