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1997
Description Amount Source
Wages $10,092 Mustang Engineering, Inc.
Wages 9,805 National Inspection
Consultants
Wages 2,800 Selectek, Inc.
Wages 600 Apollo Industrial Services,
Inc.
Interest 228 All American
Unemployment 6,011 State of Texas
compensation
Social Security 10,261 U.S. Treasury
Pension 468 International Brotherhood of
Electrical Workers
Pension 3,382 Dixie National Life Insurance,
Co.
Total $43,647
Petitioners did not file income tax returns for 1994, 1996,
and 1997. Petitioners did not pay any estimated tax in 1997.
OPINION
A. Income Tax Deficiencies
Petitioners contend that they are not liable for tax for the
years at issue because the notices of deficiency are invalid.
Petitioners contend that: (1) The Commissioner may not determine
a deficiency for a year for which a taxpayer did not file a
return; (2) petitioners’ income is not taxable because they did
not file returns; and (3) respondent did not prepare a return for
each of the years in issue that qualified as a substitute return
under section 6020(b).4 We disagree.
4 The Commissioner may prepare substitute returns for
taxpayers who fail to file returns. Sec. 6020(b)(1). A Form
(continued...)
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