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During respondent's audit of the subject years, respondent
issued a summons to the Credit Union on August 4, 1995,
requesting financial information on petitioner. Respondent did
so after his revenue agent had attempted unsuccessfully to get
the information from petitioner. Petitioner moved the U.S.
District Court of Michigan, Western District, on August 23, 1995,
to quash respondent's summons, asserting primarily frivolous
claims of constitutional violations. Petitioner stated in his
affidavit accompanying his motion that "We have no source of
income from within the United States or a State. Nor are we
engaged in a 'trade or business' within the United States". On
January 30, 1996, the District Court dismissed petitioner's
motion as frivolous and sanctioned him $250 for filing a petition
and brief as "nonsensical attempts to interfere with compliance
with a valid summons". The District Court also stated that
petitioner raised "barely intelligible claims of the kind
generally advanced in 'tax protestor' cases".
Before the subject years, petitioner had a history of filing
Federal income tax returns.
OPINION
Petitioner did not file an income tax return for any of the
subject years, and respondent determined that petitioner was
liable for the above-mentioned deficiencies and additions
thereto. Except for the additions to tax for fraudulent failure
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