- 3 - tax payments for any of the years in issue. He did not maintain any records from which the amount of his income or Federal income tax liability for any of the years in issue could be computed. Towards the end of 1992, petitioner received a letter from respondent's collection division as a result of his failure to file Federal income tax returns for 1989 and 1990. Respondent's letter, which was signed by Thomas Moore, Chief, Automated Collection Branch, indicated that petitioner had failed to respond to prior "notices" and requested that petitioner contact respondent by telephone at a number listed in the letter, or provide respondent with a telephone number where respondent could contact petitioner. Petitioner responded by letter dated January 22, 1993, that included 32 "interrogatories" requesting impertinent information, such as "who owns the IRS", and seeking Thomas Moore's address and a copy of his paycheck. Petitioner concluded his letter with a statement that unless he "received full and satisfactory answers and documents pursuant to the afore stated interrogatories * * * within 3 days from the date of this letter", he would "consider the matter closed". More correspondence between respondent and petitioner followed. Respondent repeatedly requested information related to years for which petitioner had failed to file Federal income tax returns, and petitioner repeatedly responded with letters that included "interrogatories" similar to those in his January 22, 1993, letter. The correspondence between the parties did nothing morePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011