Leogrande v. United States

Each of the nine appellants herein filed an income tax return for the year 1983 which provided only information as to his name, address, social security number, and the amount of estimated 1983 taxes paid or amount applied from his 1982 return. All other items were left blank except for the entry of “Fifth & Sixth Amendments to Constitution” on the line provided for miscellaneous income. No other neutral information or financial data was provided, nor were the returns signed or verified in any way.

The Internal Revenue Service (“IRS”) determined that the taxpayers’ returns fell within the…