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with his belief that he was not subject to the Federal income
tax.
An accountant prepared petitioner's 1985 Federal income tax
return. In 1989, respondent audited petitioner's 1985 return.
Petitioner represented himself in the audit process and did not
agree with the adjustments respondent's agent proposed or that he
owed additional tax for his 1985 tax year. Petitioner believed
that his income and deductions for 1985 had been correctly
reported. Petitioner took no further action, the additional tax
was assessed, and respondent seized petitioner's bank account for
satisfaction of the assessed deficiency. The results of his 1985
audit during 1989 made petitioner angry and frustrated. Because
of that experience and following the seizure of the proceeds of
his bank account in 1989, petitioner chose to no longer maintain
a bank account.
On June 15, 1992, respondent's agent, David Walden (Walden),
advised petitioner by letter that his 1986 through 1991 tax years
were being subjected to examination. Brenda Nelon's 1987 taxable
year was also under examination by Walden. By a June 25, 1992,
letter, Walden was advised that petitioner was under no
obligation to communicate with respondent's agents and that
petitioner was not subject to the Federal income tax. The letter
also acknowledged that petitioner did not file Federal income tax
returns for the years in question. The letter was written by
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