William Wilson - Page 3




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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, as supplemented.                                          
          Background                                                                  
               A.  Petitioner’s Forms 1040 for 1996 and 1998                          
               On or about March 27, 1997, William Wilson (petitioner)                
          submitted to respondent a Form 1040, U.S. Individual Income Tax             
          Return, for the taxable year 1996.  On the Form 1040, petitioner            
          listed his filing status as “Married filing separate return” and            
          described his occupation as “Coach Operator”.                               
               Petitioner entered zeros on applicable lines of the income             
          portion of the Form 1040, specifically including line 7 for                 
          wages, line 22 for total income, and line 31 for adjusted gross             
          income.  Petitioner also entered a zero on line 51 for total tax            
          and claimed a refund in the amount of $1,426 reflecting Federal             
          income tax withholding.                                                     
               On or about April 5, 1999, petitioner submitted to                     
          respondent a Form 1040, U.S. Individual Income Tax Return, for              
          the taxable year 1998.  On the Form 1040, petitioner listed his             
          filing status as “Married filing separate return” and described             
          his occupation as “Coach Operator”.                                         
               Petitioner entered zeros on applicable lines of the income             
          portion of the Form 1040, specifically including line 7 for                 






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