- 9 -
24. When the respondent attempted to summons
records from the Cushing Medical Clinic, Inc., and the
Creek County Health Department, petitioner Dorothy E.
Wells filed a petition to quash summons on July 13,
1990, in case number 90-C-599-B, United Stated District
Court, Northern District of Oklahoma. That petition
was dismissed upon the government's Motion For Summary
Judgment.
25. Prior thereto, on February 13, 1989, a trial
was held in the U.S. Tax Court on the petition of
Dorothy E. Wells in Docket No. 28337-87, for the
taxable years 1983, 1984 and 1985. Judgment was
entered for respondent and damages under I.R.C. � 6673
in the amount of $5,000.00 were entered against
petitioner Dorothy E. Wells. Wells v. Commissioner,
T.C. Memo. 1989-150.
26. For each of the taxable years 1986, 1987,
1988 and 1989, the petitioner Wayne E. Wells failed to
file a federal income tax return.
27. Petitioner Wayne E. Wells has not paid any
federal income tax for any of the four taxable years
1986, 1987, 1988 and 1989, except for withholding in
1986 in the amount of $2,141.00.
28. On or about July 6, 1990, petitioner Wayne E.
Wells mailed a letter to the Internal Revenue Service,
Austin, Texas, attached to which were five Forms 1040,
purported federal income tax returns for the taxable
years 1985, 1986, 1987, 1988 and 1989. A copy of the
same letter was attached to each Form 1040, and the
only difference among the letters was that the
petitioner underlined the appropriate year in the
second line of the letter. A copy of the letter (the
letter in which 1986 was underlined) is attached hereto
as Exhibit 8-H, and a copy of each of the Forms 1040
for the four years before the Court--1986, 1987, 1988
and 1989--is attached hereto as Exhibits 9-I, 10-J, 11-
K and 12-L.
29. The four identical letters included the
statement that "These returns should not be construed
to be a voluntary self assessment," and contained
additional language in which petitioner Wayne E. Wells
denied that he had any federal income tax liability for
any of the four years.
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