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income.5 Petitioner attached a Form 4852 to the Form 1040A. He
also attached a one-page untitled document and a five-page
document entitled “Asseveration of Exclusion of Remuneration from
Gross Income for 1998” in which he raised arguments similar to
those raised in the attachment to his 1997 Form 1040 and in the
Form 4852 that he submitted for 1997.
Respondent did not accept petitioner’s 1997 Form 1040 or the
1998 Form 1040A as valid returns. Respondent prepared substitute
for return documents (SFRs) for petitioner for 1997 and 1998.
Each of the SFRs consists of pages 1 and 2 of a Form 1040, and
each contains zeros on line 7 for wages and salaries, line 22 for
total income, line 39 for taxable income, line 40 for tax, and
line 56 for total tax. Respondent stamped those documents as
received by his service center on February 23, 2000. Respondent
mailed to petitioner a letter dated May 31, 2000, notifying him
of proposed changes to petitioner’s taxes and various penalties
for the years 1997 and 1998. A revenue agent’s report dated May
31, 2000, is attached to that letter. The letter informed
petitioner that he had 30 days to request a conference with
respondent’s Office of Appeals if petitioner did not agree to the
5Petitioner also entered zeros on line 35 for Federal income
tax withheld and line 39 for total payments. Line 7 contains a
handwritten notation to see an attached document for an
explanation regarding petitioner’s entry of zero on that line.
All remaining lines except the name, filing status, and the
signature lines were left blank.
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