Joseph T. McQuatters - Page 10

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            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                                   




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