-6- without assessment, at any time." Petitioners did not file a return for any of the years at issue. Consequently, the respec- tive periods of limitations applicable to those years have not expired. Petitioners also contend on brief: The tax returns for petitioners for the years 1982-1987 were prepared by respondent using information summoned from petitioners and produced by them under protest. The deficiencies claimed by respondent for the years 1982-1987 are based on the records seized from peti- tioners. Petitioners filed this appeal claiming the income attributed to them is not correct and that they were not granted the benefit of proper deductions and various elections, especially filing status. Petition- ers contend that their records were seized in violation of their right to privacy. Indeed, if a citizen has a right to privacy concerning sexual acts and the killing of an unborn child, petitioners have the right to privacy with regard to their income. Those records were used by respondent, despite petitioners' objec- tion, to * * * prepare tax returns. Petitioners dis- agree with the content of those returns. Petitioners have stated their objections. Respondent listed the person who prepared the returns as a witness, but did not call him to testify. There was no testimony or evidence introduced by respondent at the trial to substantiate income attributable to petitioners. In the absence of such testimony or evidence, the court must conclude that there are no deficiencies. We reject petitioners' position. Petitioners have not submitted any evidence, such as the records which they provided to respon- dent, that supports their general and conclusory contention that respondent's income determinations, which they concede were based on those records, are in error. Nor have petitioners supported on the record before us their general and conclusory assertion that respondent incorrectly determined the deductions and elec-Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011