- 3 - 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 petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011