- 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