- 5 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011