- 5 - provided on the form, would be a waiver of his constitutional rights. Petitioner attached two opinion letters to the return, one from an attorney and the other from an accountant, which advised that by signing a Form 1040, a taxpayer waives constitutional rights or subjects himself to criminal sanctions. Petitioner consulted and received advice from a number of tax professionals, including the two whose letters were enclosed with the 1989 return. The tax professionals each held tax protester beliefs similar to petitioner's. The opinions of tax professionals had been obtained by petitioner from outside of his own area. Petitioner had sought the advice of a local professional who declined involvement with petitioner's tax protest returns. In 1992, the Internal Revenue Service (IRS) began an examination of petitioner's 1989 tax liability. The audit expanded to include 1990, 1991, and 1992. Petitioner became aware of the audit by October 1992. In April 1993 and November 1994, after he was notified of the audit, petitioner submitted Forms 1040NR, U.S. Nonresident Alien Income Tax Return, for each of the years in issue, including the taxable year 1989 for which petitioner had filed the unsigned Form 1040. On the Forms 1040NR, dated April 12, 1993, petitioner provided his name and signed each of the forms, but he did not list his Social Security number. Petitioner provided his street address and identifiedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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