Edward J. Frami - Page 5

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                                       OPINION                                        
               Petitioner sought the jurisdiction of this Court by means of           
          a petition alleging that respondent had erred in determining                
          income tax deficiencies for petitioner's 1993 and 1994 taxable              
          years.  Petitioner refused to show his records to respondent's              
          agents, and he also refused respondent's offer to stipulate                 
          facts.  Petitioner stated that he appeared at trial for the                 
          purpose of expressing the view that the burden of proof should              
          not be on taxpayers, but instead should be on respondent.  The              
          Court explained to petitioner that the rules were well-                     
          established that he had to bear the burden of showing that                  
          respondent's determination was in error.  See Rule 142(a); Welch            
          v. Helvering, 290 U.S. 111 (1933).  It was also explained to                
          petitioner that if he did not come forward with any evidence, the           
          Court would have no choice other than to sustain respondent's               
          determination.  Petitioner stated that he was willing to bear a             
          tax burden for which he otherwise may not have been obligated in            
          order to make the point that the tax system, as statutorily                 
          configured, is unfair.                                                      
               Petitioner proceeded, under oath, to testify.  Petitioner's            
          relatively brief testimony mainly addressed his disagreement with           
          the current approach to Federal tax administration and the                  
          resolution of Federal tax controversies.  Within those comments,            
          however, petitioner stated that he had some income, but that the            





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