Gregg H. Risner - Page 4

                                        - 4 -                                         
          base year income, respondent determined that petitioner earned              
          net profits of $77,401, $79,718, and $81,759 from his                       
          chiropractic business during the taxable years 1992, 1993, and              
          1994, respectively.                                                         
               Petitioner invoked this Court's jurisdiction by filing a               
          timely petition for redetermination on September 18, 1995.3  The            
          petition states in pertinent part:                                          
               1. Petitioner specifically denies the receipt of the                   
               taxable income shown in the "Notice of Deficiency" on                  
               which the amount of the alleged deficiency was figured,                
               and, therefore, denies the deficiency and the penalties                
               because of the inaccuracies in that taxable income,                    
               and,                                                                   
               2. Petitioner pleads that there is/are no implementing                 
               regulations of the Code of Federal Regulations which                   
               give any authority to the Internal Revenue Service, or                 
               any of its officers or employees, to proceed in the                    
               manner in which it has proceeded in the instant matter,                
               and, therefore, the actions taken by the Internal                      
               Revenue Service in this matter falls outside of its                    
               scope of authority granted to it by the code, and,                     
               3. Petitioner pleads that, based upon Title 26 USC (The                
               Internal Revenue Code) and its implementing                            
               regulations, Petitioner is engaged in no taxable                       
               activities, and is therefore outside the jurisdiction                  
               of the Internal Revenue Service, and,                                  
               4. Petitioner pleads that the burden of proving the                    
               non-receipt of income is beyond the reasonable burden                  
               which the Court should place on an individual, and                     
               5. Petitioner pleads that the entire case by the                       
               Government is based upon a "naked assertion", i.e. one                 
               person's word against another's, and therefore is                      
               insufficient to sustain a decision in the Government's                 
               favor.                                                                 



               3  At the time he filed his petition, petitioner was                   
          residing in Longview, Texas.                                                


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