- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011