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Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioner resided
in Dothan, Alabama.
On or about April 15, 2001, petitioner filed with respondent
a Form 1040, U.S. Individual Income Tax Return, for 2000 (Form
1040). On the Form 1040, petitioner reported zero wages, zero
total income, and zero taxable income, and he claimed a refund of
Federal income tax withheld in the amount of $7,940. On the last
page of his Form 1040, petitioner listed his occupation as
“Labor”.
On October 28, 2002, respondent issued petitioner a notice
of deficiency for 2000. Based on information returns, respondent
determined that petitioner failed to report wages from Great
Northern Nekoosa Corp. (GNNC) of $51,824, interest from Five Star
Credit Union of $54, and total rental income of $3,022, which
amount consisted of $2,380 from Paden Realty & Appraisals, Inc.,
and $642 from Housing Authority of the City of Dothan, Alabama.
Respondent further determined that petitioner is liable for the
accuracy-related penalty under section 6662(a) for a substantial
understatement of tax.
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