Ghalardi Income Tax Education Foundation - Page 19

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                  Third, petitioners argue that "even if the deficiency               
             notices sent by IRS were valid, any additional assessments               
             that they would have created would be invalid."  According               
             to Mr. Webber, this is true because respondent "has no                   
             delegated authority to prepare returns for Petitioner and,               
             therefore, no legal deficiency notices are possible in the               
             instant case where Petitioner did not self-assess himself."              
                  Fourth, petitioners argue that "any returns provided                
             by Respondent that were prepared by a revenue officer in                 
             the San Jose office of Internal Revenue will not conform                 
             to 26 USC 6065 because such returns are not authorized by                
             law nor are they affirmed under penalties of perjury."                   
             Similarly, petitioners argue that respondent's agent                     
             violated the law "by failing to provide a lawful signature               
             on his information reports" as required by section 6065.                 
             Petitioners charge that, by completing the statements of                 
             income tax examination changes that are attached to the                  
             notices of deficiency and by filing those statements as                  
             "substitute returns" for petitioners under section 6020(b),              
             respondent's agent has "made an attempt to extort sums"                  
             from petitioners in violation of section 7214.                           
                  Fifth, petitioners assert that under our system of                  
             taxation, "the only way Internal Revenue can legally                     
             collect an income tax from an individual citizen * * *                   





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