John F. Dalton - Page 3

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          as a matter of law.  Accordingly, we shall grant respondent’s               
          Motion for Summary Judgment.                                                
          Background                                                                  
               Petitioner submitted to respondent Federal income tax                  
          returns for 1998 and 1999 in which he entered zeros on all lines            
          requesting information regarding his income.  Petitioner attached           
          to his tax return for 1998 a Form W-2, Wage and Tax Statement, in           
          which Smith Security Corp. reported that it paid petitioner wages           
          of $8,901.12 during 1998.  Petitioner also attached to his tax              
          return for 1998 a two-page statement raising frivolous and                  
          groundless challenges to the Federal income tax.                            
               Respondent issued separate notices of deficiency to                    
          petitioner for the taxable years 1998 and 1999 on February 16,              
          2001 (deficiency notices).  In the notice for 1998, respondent              
          determined a deficiency in income tax of $433 and an addition to            
          tax of $108.25 under section 6651(a)(1) for failure to file                 
          timely.  The deficiency for 1998 was based on respondent’s                  
          determination that petitioner failed to report $8,901 of wages              
          received from Smith Security Corp., $925 of a taxable                       
          distribution received from Textron, Inc., and $18 of interest               
          received from NBD Bank.  In the notice for 1999, respondent                 
          determined a deficiency in income tax of $2,254 and an addition             
          to tax of $563.50 under section 6651(a)(1).  The deficiency for             
          1999 was based on respondent's determination that petitioner                






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