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his income was taxable or whether he was required to file an
individual income tax return.
On May 4, 2000, petitioner personally prepared and filed
Forms 1040X, Amended U.S. Individual Income Tax Return, for the
1996, 1997, and 1998 taxable years reporting zero income and
claiming refunds. In addition to the amended individual income
tax returns that petitioner filed, petitioner also sent letters
to his payors on April 14, 2000, stating that they had
erroneously reported income to the Internal Revenue Service (IRS)
and directing that they file corrected information returns with
the IRS reflecting that he had no gross income.
Petitioner also filed Forms 4852, Substitute for Form W-2,
Wage and Tax Statement, or Form 1099R, Distributions from
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRA’s,
Insurance Contracts, Etc., with the amended individual income tax
returns he filed on May 4, 2000. On those Forms 4852 petitioner
reported that he had zero income from each payor for the 1996,
1997, and 1998 taxable years.
On May 19, 2000, the IRS sent petitioner a letter informing
him that the amended individual income tax returns he filed for
the 1996, 1997, and 1998 taxable years were determined to be
frivolous documents, that the positions taken on the amended
income tax returns were frivolous, and that his refund claims
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