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income from stock sales were includable in gross income; (3) he
had itemized deductions in the amounts of $31,060, $40,354, and
$37,704 for 1989 to 1991, and a standard deduction in the amount
of $3,600 for 1992; and (4) he was liable for additions to tax
for failure to file returns and failure to pay estimated tax for
1989 to 1992. In the petition, petitioner also contended: (1)
Respondent's answers to his inquiries were not courteous or
considerate, and (2) respondent violated his rights under the
Taxpayer Bill of Rights, subtitle J of the Technical and
Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, 102
Stat. 334, and other rights.
The facts upon which petitioner relies in his petition to
support these contentions are:
he was never notified by the District Director that he
was required to maintain books and records and file a
return in accordance with IRC 6001 and 26 CFR 1.
6001(d);
* * * the Form 1040 is not associated with nor is it
the form required to be used to collect the income tax
under IRC Subtitle A, section 1;
* * * there has been a trespass of jurisdiction on the
part of the Commissioner and petitioner squarely
challenges the Commissioner's jurisdiction in issuing
these notices of deficiency.
Nothing listed by petitioner as facts could possibly justify
a holding that respondent's determinations are incorrect.
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Last modified: May 25, 2011