Elliot Virgil Wilkerson - Page 4

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               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                  
               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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