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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 more
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