Rosa Janus - Page 6

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          subject examination of petitioner's tax liability for those                 
          years.  Respondent has not made any tax assessment for those same           
               In statutory notices of deficiency, respondent determined              
          deficiencies in petitioner's Federal income tax for the years               
          1986 through and including 1991.  Respondent also determined                
          additions to tax under section 6651(a) for failure to file a                
          return for each of those years, and under section 6654(a) for               
          failure to pay estimated taxes for 1989, 1990, and 1991.                    
          Respondent's determinations as to petitioner's tax liability are            
          presumed correct, and petitioner has the burden of proving                  
          otherwise.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115              
               Petitioner asserts frivolous tax protester-type arguments              
          that essentially ask this Court to "look behind" the notices of             
          deficiency and find them arbitrary and excessive.  Petitioner               
          argues that the notices of deficiency and the determinations                
          therein are invalid because respondent:  (1) Failed to identify             
          the type of tax involved; (2) improperly prepared for petitioner            
          tax returns that did not satisfy the requirements of section                
          6020; (3) failed to follow Internal Revenue Manual procedures and           
          did not identify the statute or regulation relied upon in issuing           
          the statutory notices; (4) misclassified her source of income;              
          and (5) did not issue the notices within the statutory                      

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