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petitioners are liable for the penalty as determined by
respondent.
FINDINGS OF FACT
Petitioners resided in Los Angeles, California, at the time
that they filed their petition. On December 23, 1991, petitioner
Jorge V. Geaga (petitioner) wrote to the Department of the
Treasury with respect to a notice that he owed Federal income
taxes and a penalty for 1990, explaining petitioner's theories
why certain items should be deductible notwithstanding contrary
legal precedent, and requesting a hearing before a Tax Court
judge. Thereafter, petitioner commenced an intensive letter-
writing campaign concerning the amounts that he wished to claim
as business deductions. Over the years, petitioner's letters
became increasingly threatening and accusatory, demanded greater
refunds, and repeated his request for a hearing before a Tax
Court judge.
Petitioners filed two prior cases in this Court, docket No.
9749-93, with respect to their Federal income taxes for 1990, and
docket No. 18569-93, with respect to their Federal income taxes
for 1991. The petition in docket No. 9749-93 was filed May 17,
1993. That case was set for trial but was continued on
respondent's motion without objection by petitioners. On
November 22, 1994, a decision was entered in that case pursuant
to a stipulation signed by petitioners. As a result of allowance
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