Linda Sanders - Page 3

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          estimated income tax payments, nor was tax withheld from her 1993           
          wages.  On or about March 31, 1993, petitioner began working as a           
          full-time paralegal for The Pilot Connection Society, also known            
          as the Liberty Foundation of Parker, Colorado (Liberty                      
          Foundation).                                                                
               During the years in issue, petitioner was associated with an           
          attorney, Harmon Taylor (Mr. Taylor).  Petitioner and Mr. Taylor            
          discussed whether petitioner was required to file Federal income            
          tax returns.  Petitioner received documents from Mr. Taylor that            
          related to a State court proceeding in Texas.  Petitioner was not           
          a party to the Texas proceeding, but The Pilot Connection Society           
          was associated with the case.  The documents concerned tax                  
          protester type materials, and petitioner relied on these                    
          documents in her decision not to file tax returns.                          
               Petitioner had also written to the Internal Revenue Service            
          (IRS) asking "tax protester type questions" regarding her tax               
          liability, to which the IRS did not respond.  In January 1994,              
          petitioner received a form letter from the IRS that informed her            
          that she may not have to file a tax return.  It contained the               
          statements:                                                                 
                    You may not have to file a Federal tax return this                
               year.                                                                  
                    According to our records, last year you were not                  
               required to file a Federal tax return.  If you have the                
               same sources of income and about the same amount of                    
               income this year as you did last year, you probably                    
               don't have to file this year either.                                   




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