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D, Capital Gains and Losses. Petitioner contends that he was
unable to follow the instructions he received over the telephone
and needed to be shown in person how to fill out his tax return.
Petitioner did not file a tax return for 2000.
Respondent issued a notice of deficiency on March 22, 2004,
determining the deficiency and additions to tax set forth above.
Petitioner filed a timely petition disputing the deficiency and
additions to tax.
OPINION
I. Contentions of the Parties
Petitioner contends that he believed he was not required to
file a Federal income tax return for 2000 because he did not
generate sufficient income. Petitioner further contends that he
is unable to file a Federal income tax return for 2000 due to his
inability to understand and complete the requisite forms and lack
of help from the IRS in completing the forms. Petitioner also
asserts that his deteriorating financial condition prevented him
from seeking professional assistance.
Respondent contends that petitioner knew that he was
required to file a Federal income tax return for 2000 because of
interest income, rental income, and gain from the sale of stock
and a commercial property. Respondent further contends that
petitioner was capable of completing a Federal income tax return
for 2000. Petitioner knew the amount he paid for the commercial
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