- 4 - the legal definition of “income”, if I were to swear to having received any other amount of “income”, I would be committing perjury * * *. So, not wishing to commit perjury * * * I can only swear to having “zero” income for 1997. [Reproduced literally.] On or about April 15, 1999, petitioner filed a tax return for his taxable year 1998 (1998 return). In his 1998 return, petitioner reported total income of $0 and total tax of $0. Petitioner attached a three-page document to his 1998 return (petitioner’s attachment to his 1998 return), which was very similar to petitioner’s attachment to his 1997 return. On August 3, 2000, respondent issued to petitioner a notice of deficiency (notice) with respect to his taxable years 1997 and 1998, which he received. In that notice, respondent determined a deficiency in, and an accuracy-related penalty under section 6662 on, petitioner’s tax (1) for his taxable year 1997 in the respec- tive amounts of $2,104 and $421 and (2) for his taxable year 1998 in the respective amounts of $2,021 and $404. Petitioner did not file a petition in the Court with respect to the notice relating to his taxable years 1997 and 1998. Instead, on October 30, 2000, in response to the notice, peti- tioner sent a letter (petitioner’s October 30, 2000 letter) to the Internal Revenue Service. That letter stated in pertinent part: Your Deficiency Notice dated August 3, 2000 According to your “Deficiency Notice” of above date (cover sheet [page 1 of notice with respect toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011