Richard Scott Gehrs - Page 4

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          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)           






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