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liability for 2000. Petitioner responded to this letter on
October 20, 2002, by filing a Form 1040X, Amended U.S. Individual
Income Tax Return. Across lines 1-10 of the Form 1040X,
petitioner wrote the words, “Not Liable.” He also wrote “Not
Liable” on line 19 of the Form 1040X. On line 23, the amount
that petitioner wanted as a refund, he wrote “$317.” In Part II
of the Form 1040X, petitioner wrote the following as an
explanation of the changes he made on the Form 1040X:
“Not Liable! (Explanation!) Not Liable!
Not Liable! I discovered after reading your 1040
instruction book that I’m not liable because line
#7 ask [sic] for my foreign source income; since I
had no foreign source income I’m not liable for
any tax you claim that I owe. Please refund my
overpayment in the amount of $317 that was
withheld.”
Respondent, by means of certified mail dated June 18,
2003, sent a notice of deficiency (the notice) to
petitioner, determining an income tax deficiency and
proposing additions to tax for the taxable year 2000 as
follows:
Deficiency Additions to tax
Sec. 6651(a)(1) Sec. 6654(a)
$6,419 $1,525.50 $324.07
The deficiency in income tax is based on respondent’s
determination that in 2000 petitioner received, but failed
to report on an income tax return for that year, income from
the following sources:
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Last modified: May 25, 2011