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During taxable years 2002 and 2003, the years in issue,
petitioner worked for Stull, Stull, & Brody, Attorneys at Law.
During 2002, petitioner received compensation in the amount of
$74,808.96, which Stull, Stull, & Brody reported on a Form 1099-
MISC, Miscellaneous Income. During 2003, petitioner received
compensation from Stull, Stull, & Brody in the amount of
$61,888.05. This amount was also reported on a Form 1099-MISC.
Petitioner never supplied Stull, Stull, & Brody with a
completed Form W-4, Employee’s Withholding Allowance Certificate.
Petitioner was aware that the firm was not withholding any
amounts from his paychecks.
For each year in issue petitioner submitted to respondent a
Form 1040, U.S. Individual Income Tax Return. These returns
indicated the names of petitioner and his wife, listed their
address and Social Security numbers, indicated joint filing
status, contained petitioner’s and his wife’s signatures, and
included no financial information. The Forms 1040 had the words
“not liable” written on the heading and other parts of the
returns.
Respondent treated petitioner as a nonfiler and prepared
substitutes for returns for 2002 and 2003. On January 3, 2005,
respondent issued a statutory notice of deficiency for
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Last modified: November 10, 2007