- 3 -
Respondent sent petitioner notices requesting that petitioner
file a Federal income tax return for the 1997 taxable year.
In letters dated December 6, 1999, and September 8, 2000,
petitioner informed respondent that, pursuant to section
6012(a)(1)(A)(i) and the instructions for Form 1040, U.S.
Individual Income Tax Return, he was not required to file a tax
return for 1997 because his gross income was less than $6,800.
Specifically, petitioner claimed that his gross income for 1997
was $6,113.78.
Respondent sent petitioner a letter dated October 5, 2000,
which stated in part:
Your investment companies only report your sales amount
to the IRS, we do not know what your original purchase
amount was. I am sure your [filing of a] Form 1040 and
Schedule D would clear your account. Thank you for
your cooperation.
Respondent then sent petitioner a so-called 30-day letter dated
July 10, 2001, proposing an individual income tax assessment for
the 1997 taxable year.
In a letter dated July 26, 2001, petitioner reiterated his
position that, pursuant to section 6012(a)(1)(A)(i) and the
instructions for Form 1040, he was not required to file a tax
return for 1997. Petitioner did not include any information from
which to verify his base in the stocks and bonds sold in 1997.
Respondent determined a deficiency in petitioner’s Federal
income tax of $1,691, an addition to tax under section 6651(a)(1)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011