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provided on the form, would be a waiver of his constitutional
rights. Petitioner attached two opinion letters to the return,
one from an attorney and the other from an accountant, which
advised that by signing a Form 1040, a taxpayer waives
constitutional rights or subjects himself to criminal sanctions.
Petitioner consulted and received advice from a number of tax
professionals, including the two whose letters were enclosed with
the 1989 return. The tax professionals each held tax protester
beliefs similar to petitioner's. The opinions of tax
professionals had been obtained by petitioner from outside of his
own area. Petitioner had sought the advice of a local
professional who declined involvement with petitioner's tax
protest returns.
In 1992, the Internal Revenue Service (IRS) began an
examination of petitioner's 1989 tax liability. The audit
expanded to include 1990, 1991, and 1992. Petitioner became
aware of the audit by October 1992. In April 1993 and November
1994, after he was notified of the audit, petitioner submitted
Forms 1040NR, U.S. Nonresident Alien Income Tax Return, for each
of the years in issue, including the taxable year 1989 for which
petitioner had filed the unsigned Form 1040. On the Forms
1040NR, dated April 12, 1993, petitioner provided his name and
signed each of the forms, but he did not list his Social Security
number. Petitioner provided his street address and identified
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