Don H. Wisden - Page 3

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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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