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Background
A. Petitioner’s Form 1040 for 1997
On or about April 15, 1998, petitioner submitted to
respondent a Form 1040, U.S. Individual Income Tax Return, for
the taxable year 1997. On his Form 1040, petitioner listed his
filing status as single and described his occupation as
“technical skills trainer”.
Petitioner entered zeros on every line of the income section
of his Form 1040, specifically including line 7 for wages, line
16 for pensions and annuities, and line 22 for total income.
Petitioner also entered a zero on line 39 for tax and a zero on
line 53 for total tax. Petitioner then claimed a refund in the
amount of $11,229 consisting of withheld Federal income tax.
Petitioner attached to his Form 1040 a Wage and Tax
Statement, Form W-2, and three Forms 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc. The Form W-2 was from Kerr-McGee
Chemical Corp.; it disclosed the payment to petitioner of wages
in the amount of $46,659.17 and the withholding of Federal income
tax in the amount of $9,253.02. The first Form 1099-R was from
Defense Finance and Accounting Service; it disclosed the payment
to petitioner of a taxable distribution in the amount of
$17,696.88 and the withholding of Federal income tax in the
amount of $1,859.28. The second Form 1099-R was from Putnam
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Last modified: May 25, 2011