- 3 - W-2, Wage and Tax Statement (Form W-2), reporting wages, tips, and other compensation totaling $14,857.07. Petitioners also attached a document to their 1994 Form 1040 (petitioners’ attach- ment to their 1994 Form 1040) that contained statements, conten- tions, and arguments that the Court finds to be frivolous and/or groundless.3 On April 13, 1996, petitioners mailed to respondent Form 1040 for their taxable year 1995 (1995 Form 1040). Above their signatures appearing in their 1995 Form 1040, petitioners struck from the jurat clause the words “Under penalties of perjury”. Because petitioners struck those words, respondent concluded that petitioners’ 1995 Form 1040 was not a valid tax return.4 In their 1995 Form 1040, petitioners reported total income of $0 and total tax of $0 and claimed a refund of $1,052 of tax withheld. Petitioners attached to their 1995 Form 1040 Form W-2, reporting wages, tips, and other compensation of $17,121.94. Petitioners also attached a document to their 1995 Form 1040 (petitioners’ attachment to their 1995 Form 1040) that contained statements, contentions, and arguments that the Court finds to be 3Petitioners’ attachment to their 1994 Form 1040 is very similar to the documents that certain other taxpayers with cases in the Court attached to their tax returns. See, e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C. Memo. 2003-45. 4On Jan. 15, 1998, respondent prepared a separate substitute for return for each petitioner with respect to the taxable year 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011