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Background1
Petitioners are husband and wife. At the time of the filing
of the petition, petitioners resided in Las Vegas, Nevada.
On or about May 12, 1998, petitioners filed a 1997 Form
1040, U.S. Individual Income Tax Return (tax return), reporting
zero gross income for the 1997 tax year. With the tax return,
petitioners submitted a 1997 Form 1099-R, Distributions from
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc., and a 1997 Form W-2, Wage and Tax
Statement. The Form 1099-R reported a gross distribution from
E.I. Dupont Pension Fund of $27,504, and the Form W-2 reported
compensation from E.I. Dupont De Nemours and Co. of $342.
Petitioners also submitted with the tax return a document making
the following assertions: (1) The Internal Revenue Code does not
establish an income tax liability; (2) the tax return is not
1Stipulations of fact signed by petitioners’ former counsel
on Feb. 13, 2004, were submitted by respondent as an exhibit to
the instant motion for summary judgment. In their response to
the motion, petitioners stated:
Due to the uncompleted process regarding the
stipulations, and since there are inadvertent errors in
the list that has been signed by both counsels,
petitioners respectfully request permission to withdraw
all stipulations attached to respondent’s motion for
summary judgment.
Because the foregoing stipulations of fact have not been filed
with this Court pursuant to Rule 91, we do not consider
petitioners’ request for withdrawal and we do not consider the
stipulations of fact contained in the exhibit.
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Last modified: May 25, 2011