- 10 - prior to and during the trial cannot be characterized as the behavior of a taxpayer fully cooperating with the IRS. Prior to the trial, in response to a letter from respondent's agent requesting an appointment with petitioner to discuss petitioner's 1988 income tax liability, petitioner sent a document, dated June 1, 1995, captioned "Certified Demand for Proof of Jurisdiction" in which he challenged the jurisdiction of the Internal Revenue Service over him and alleged that he is "a Sovereign Citizen of the South Carolina Republic," but not "a citizen of the United States subject to its jurisdiction." Then, after receipt of respondent's report of Income Tax Examination Changes, Form 4549, petitioner returned the Form 4549 to the IRS district director in Doraville, Georgia, and declared in the accompanying letter dated December 8, 1995, that he was a "Nonimmigrant/Nonresident Alien Nontaxpayer". Petitioner's December 8, 1995, letter to the district director included numerous citations of the Uniform Commercial Code that have no relevance to this case. On the basis of the evidence before us, we conclude that petitioner has not asserted a "reasonable dispute with respect to any item of income" that was reported to respondent as having been paid to and/or earned by petitioner and has not shown that he "fully cooperated" with respondent. See Dennis v. Commissioner, supra; Hardy v. Commissioner, supra. Therefore, the burden of going forward and producing "reasonable andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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