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property, and the addition to tax under section 6651(a)(1)
(respondent’s motion).2
Background
Petitioners resided in Temecula, California, at the time
they filed the petition.
On December 5, 1997, respondent filed a request for
admissions with the Court, a copy of which respondent had served
on petitioners on December 2, 1997. On January 7, 1998,
petitioners filed a response to respondent’s request for
admissions, a copy of which petitioners had served on respondent
on January 2, 1998. That response stated, inter alia:
Admissions OF WHAT?
I request your (DOA) or (TDO) DELEGATION OF
AUTHORITY Order from the Secretary of the Treasury.
* * * * * * *
On Feb. 27, 1986 the Federal Register (51 Fed. Reg.
95711) published the following Treasury Department
Order No. 150-01:
“The Commissioner shall, to the extent of
authority otherwise vested in him, provide for the
administration of the United States internal revenue
laws in the U.S. Territories and insular possessions
and other authorized areas of the world.” [These areas
include countries with which the U.S. has Tax Treaties
in force and DO NOT include the 50 Republic States.]
2 Issues not covered by respondent's motion are whether
petitioners (1) have $3,480 of unemployment compensation for
1992, (2) are entitled to any deductions for 1992, 1993, 1994,
and 1995 (the years at issue), (3) are subject to self-employment
tax for 1992 and 1993, and (4) are liable for the years at issue
for the accuracy-related penalty under sec. 6662(a).
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Last modified: May 25, 2011