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Watson, Inc., letter, petitioner acknowledges that he will be
paid money for working for Watson, Inc., during 1998 but, in
part, he justifies his claim that he is not subject to employment
taxes on the basis that he anticipates that he will incur no
liability for income tax for 1998. In 1998, petitioner received
$48,000 from Watson, Inc., that, beyond peradventure, is an item
of gross income, reportable, but not reported, on his 1998
Federal income tax return. We view the attachment to the 1998
Form 1040, and, in particular, petitioner’s unsupported and
unjustified anticipation that he will incur no tax liability for
1998, as raising a serious question as to whether the 1998 Form
1040 was an honest and reasonable attempt to satisfy the
requirements of the tax law, and we conclude, and find, that it
was not.
On the basis of Sloan v. Commissioner, supra, Beard v.
Commissioner, supra, and Lange v. Commissioner, supra, we hold
that neither the 1998 nor 1999 Form 1040 constituted a reasonable
attempt to satisfy the requirements of the tax law. Therefore,
neither constituted a valid return, and petitioner is liable for
the 25-percent addition to tax under section 6651(a)(1) for
failure to timely file a return for 1998 and 1999.
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