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of the years in issue, petitioner did not meet with respondent's
agents and failed to provide records to respondent in connection
with the examination of his tax liability. Petitioner's answers
to respondent's discovery were inadequate. In addition,
petitioner submitted six discovery requests to respondent that
concerned irrelevant tax protester matters that have no
meaningful relationship to respondent's determination of
petitioner's income tax liability, additions to tax, and
penalties. Petitioner maintained tax protester arguments in the
documents he submitted to the IRS and in his testimony at trial
even though he knew that this Court has held the arguments to be
frivolous.
OPINION
At trial, petitioner conceded that if the Court finds him
subject to Federal income tax, he had adjusted gross income from
his veterinary practice of $65,000 in each of the years in issue.
Petitioner also conceded that he received interest and dividend
income and short-term capital gain in 1992. At trial, petitioner
expressed various tax protester arguments that are without merit
and have often been rejected by this Court. Petitioner did not
present any evidence concerning respondent's determination that
he is subject to self-employment tax under section 1401 on the
$65,000 income from his veterinary practice for each of the years
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