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premature distribution from an individual retirement account, a
distribution from the Oregon Public Employees Retirement Fund,
and capital gains from the sale of mutual funds and real estate.
Petitioners filed a petition with this Court on April 19,
1996. The gist of petitioners' allegations in their petition is
that (1) petitioners are "American citizens and residents
(Domestic) and not united states citizens and/or residents
(National)"; (2) that this case can only be heard by an Article
III court;2 (3) that the issuance of the notice of deficiency was
an abuse of discretion by the Commissioner; (4) that the
Commissioner erroneously and arbitrarily determined that
petitioners were "taxpayers", that they received "taxable
income", and that they were engaged in a "taxable activity"; (5)
that petitioners have been denied adequate notice and a
meaningful opportunity to be heard at the administrative level;
(6) that petitioners have been denied certain procedural
safeguards guaranteed to them as "sovereign citizens of one of
the several Sovereign Republican states of the Continental States
United"; (7) that petitioners have been labeled "tax protesters";
and (8) that the additions to tax under sections 6651 and 6654
are confined to alcohol, tobacco, and firearms revenue.
2 Petitioners did not explain why they filed a petition in
an Article I court. They could have paid the deficiencies and
additions to tax and filed a claim for refund, and, if
disallowed, sued for refund in an Article III Court.
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