Kenneth O. and April C. Butler - Page 5




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               basis for resisting the tax.  [United States v. Lee,                   
               455 U.S. 252, 260 (1982).]                                             
          See also Anthony v. Commissioner, 66 T.C. 367, 373 (1976), affd.            
          without published opinion 566 F.2d 1168 (3d Cir. 1977); Egnal v.            
          Commissioner, 65 T.C. 255, 262 (1975); Russell v. Commissioner,             
          60 T.C. 942, 945 (1973); Muste v. Commissioner, 35 T.C. 913, 918-           
          919 (1961).                                                                 
               Petitioners next mention that their Fourth Amendment rights            
          would be violated by filing Federal income tax returns.                     
          Petitioners have not shown that the Fourth Amendment has any                
          relevance to these facts, and we perceive no basis upon which it            
          could.                                                                      
               Finally, petitioners argue that their Fifth Amendment rights           
          would be violated by filing Federal income tax returns.  The                
          Fifth Amendment privilege against self-incrimination protects an            
          individual from being compelled to disclose information that                
          could reasonably be expected to furnish evidence needed to                  
          prosecute the claimant for a crime.  See Kastigar v. United                 
          States, 406 U.S. 441, 445 (1972); Hoffman v. United States, 341             
          U.S. 479, 486 (1951).  The requirements that petitioners shall              
          prepare and file their tax returns do not violate the Fifth                 
          Amendment privilege against self-incrimination.  See United                 
          States v. Sullivan, 274 U.S. 259 (1927); Kasey v. Commissioner,             
          457 F.2d 369, 370 (9th Cir. 1972), affg. per curiam 54 T.C. 1642            






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