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plead her allegations of fact with sufficient specificity that
the Court can conduct a meaningful hearing to determine whether
respondent can proceed with collection of her liability.
Poindexter v. Commissioner, supra at 285.
Petitioner’s statements indicate that she disagrees with the
income tax liability as shown on the joint return. However,
other than claiming that the joint return contained false or
fraudulent information, petitioner fails to specifically address
or identify any items of income, deduction, or credit or any
calculations that are incorrect. In fact, respondent has not
challenged the $7,376 in Schedule C expenses claimed on the filed
1996 tax return.11 In short, as to computational matters,
petitioner has failed to aver facts or to establish facts at
trial with credible evidence sufficient to show any error in
respondent’s assessment. Petitioner’s only explicit argument
contesting her underlying tax liability is her contention that
11 Petitioner stated that she had gross income of $11,000
and incurred $8,000 in expenses for papers and supplies in
connection with her newspaper delivery business. However, at
trial, she orally listed expenses of: $7,405 for papers, $140
for an expense not mentioned, and $300 for her bond. These
amounts total $7,845, none of which was substantiated by
petitioner. Petitioner did not submit any evidence regarding any
of her deductions, yet respondent never disallowed any of the
$7,376 in expenses claimed on petitioner’s Form 1040, Schedule C.
It appears that petitioner attempted to file a Form 1040 because
she believed she was entitled to a refund of her $900 in tax
credits. She apparently thought that she only had income of
approximately $3,000, was, therefore, not liable for any tax, and
had no obligation to file a return. This was an erroneous belief
since an individual’s obligation to file a tax return depends
upon on gross income, not net income. See sec. 6012(a)(1)(A);
see also supra sec. II.
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