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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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