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directing the City to withhold at single taxpayer rates with no
allowances until a new Form W-4 was filed with a reasonable number
of allowances claimed. The City complied with the IRS'
instructions.
On March 16, 1992, petitioner filed a Form W-4 with the City
claiming 31 allowances. After the City did not honor this new Form
W-4, petitioner filed bogus liens against various city employees
(including the City payroll clerk) and IRS employees. He also
filed a lawsuit against the City and the payroll clerk. The City
defended the lawsuit; the liens were expunged, and a judgment was
entered against petitioner.
In December 1992, petitioner and Mrs. Simmons executed a
declaration of trust purporting to convey their personal residence
to themselves as trustees for the benefit of their children.
This case previously had been calendared for trial at the
session in Boise beginning on May 22, 1995. On May 19, 1995,
petitioner and Mrs. Simmons filed a voluntary petition for
bankruptcy under chapter 13, thus halting the proceedings in this
case. Petitioner and Mrs. Simmons did nothing to prosecute the
bankruptcy case, and that case was dismissed for failure to file a
plan and failure to file tax returns.
On March 6, 1995, respondent filed a motion for an award of a
penalty under section 6673. On March 29, 1995, petitioner filed a
document entitled "Administration Law Demand for Dismissal of
Notice of Deficiency by the Commissioner of the Internal Revenue".
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