Michael A.Cabirac - Page 6

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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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