Robert E. Dunham - Page 5

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          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 identified              





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