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accuracy-related penalty under 6662(a) and (b)(1) because
petitioner’s Form 1040, U.S. Individual Income Tax Return, did
not constitute a valid return.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of
facts and the attached exhibits are incorporated herein by this
reference. Petitioner resided in Atlanta, Georgia, at the time
his petition was filed.
During 1999, petitioner was employed by Primerica Financial
Services, Inc. (PFS). At some point before 1999 petitioner
submitted Form W-4, Personal Allowances Worksheet, to PFS
instructing that PFS not withhold Federal income taxes from his
compensation.
Petitioner filed Form 1040 for the 1999 tax year.3
Petitioner did not enter on the form any financial information
for the tax year but instead entered zeros on every line
regarding income and reported his total income for 1999 as zero.
Petitioner’s 1999 filing status was married filing separately,
and he claimed the standard deduction on the basis of his filing
status. Petitioner also claimed personal exemptions for himself
and his spouse, and a dependency exemption for his daughter.
3 We are unable to discern from the record whether
petitioner’s Form 1040 was timely filed, because it was stamped
“Received” by an Internal Revenue Service on July 20, 2000, even
though petitioner signed and dated it Apr. 15, 2000.
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