Clyde E. Owens and Marie W. Owens - Page 16

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          IRS agent, for which Mr. Owens was indicted, tried, and acquitted           
          in 1977.  Mr. Owens also testified that the IRS seized more than            
          $12,000 from Ms. Feltrinelli on dates not specified in the                  
          record.  Petitioners contend that respondent's agents acted                 
          improperly during the audit.  Petitioners criticized respondent's           
          original auditor and charged that McEver and McGovern (an                   
          otherwise unidentified person) conspired against Mr. Owens and              
          Ms. Feltrinelli to deprive them of their records.  Mr. Owens                
          offered no meaningful details about or corroboration of his                 
          claims.                                                                     
               Petitioners have not shown that respondent's agents were               
          abusive to them, acted improperly, or had a vendetta against them           
          in any way.                                                                 
               2.   Petitioners' Constitutional and Civil Rights                      
               Petitioners contend that they are entitled to relief from              
          liability for the income tax deficiencies and penalties at issue            
          in these cases because respondent violated their rights under the           
          1st, 4th, 5th, 7th, 8th, and 14th Amendments to the U.S.                    
          Constitution and various Civil Rights Acts.                                 
               Petitioners contend that respondent violated their rights              
          under the 1st Amendment of the U.S. Constitution by retaliating             
          against Mr. Owens because he pledged in his Congressional                   
          campaign to place the burden of proof in tax cases on the IRS.              
          Petitioners contend that their right to be secure in their papers           
          and protected against unreasonable search and seizures under the            




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