- 3 -- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011