Wilson D. Watson - Page 22




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          to file a valid return for each year.  For 2001 and 2002, there             
          is no dispute that petitioner’s filing status was “single”.                 
          Therefore, his return filing thresholds for those 2 years as a              
          single taxpayer under age 65 (see supra note 9) were $7,450 (for            
          2001) and $7,700 (for 2002), amounts that exceed his gross income           
          for each of those years, as redetermined herein:  $3,342.12.  As            
          a result, petitioner was not required to file a return for either           
          2001 or 2002.                                                               
                    3.  1998 and 1999                                                 
               While petitioner’s additions of the qualification “under               
          protest without prejudice” between the jurat and his signature on           
          both the 1998 and 1999 Forms 1040, and his addition of the margin           
          language to his 1999 Form 1040, may not amount to a disclaimer of           
          tax liability or a negation of the jurat, we cannot say the same            
          with respect to the effect of the attachment to each Form 1040.             
          Petitioner referred to the attachment to the 1998 Form 1040 on              
          line 7 of that form, and he referred to the attachment to the               
          1999 Form on both line 7 of that form and in the margin language.           
               In Sloan v. Commissioner, 102 T.C. 137 (1994), affd. 53 F.3d           
          799 (7th Cir. 1995), the taxpayers, after the jurats and before             
          their signatures on Forms 1040 submitted for several years, added           
          a reference to an accompanying statement of “denial and                     
          disclaimer”, by which statement they erroneously denied any                 
          Federal income tax liability for the year.  We stated that the              







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