- 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 and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011