- 3 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011