David M. Leggett - Page 6

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               Should you fail to telephone us within the 10 day                      
               period, you will leave us no choice but to proceed with                
               other actions to bring you into compliance with the tax                
               laws.  This may include preparation of a report based                  
               upon information currently in our possession, and                      
               assessing any taxes, interest, and penalties for the                   
               year involved.                                                         
               If you have previously filed returns for the years                     
               shown above, or have returns completed that can be                     
               processed as delinquent returns, please inform us at                   
               the time you telephone.  You will be asked to provide                  
               copies of the returns previously filed, or the del-                    
               inquent returns prepared and not filed.  [Fn. added.]                  
               Shortly after the August 30, 1995 letter was sent to pe-               
          titioner, petitioner telephoned the revenue agent to request a              
          meeting which he would be allowed to record by taping it with his           
          tape recorder.  In September 1995, the revenue agent and another            
          revenue agent of the Service met (September 1995 meeting) with              
          petitioner, his father William Leggett, and another individual              
          named Toby Brown.  Petitioner brought some papers with him to the           
          September 1995 meeting, and he started to read frivolous ar-                
          guments from those papers about his being a nonresident alien.              
          He also questioned the authority of the Service over him.  The              
          revenue agents attempted to ask petitioner several questions at             
          the September 1995 meeting in order to ascertain his income and             
          similar information that they needed to determine his tax lia-              
          bility for the years for which he did not file returns.  However,           
          petitioner refused to answer those questions.  Instead, he                  
          continued to read from the papers that he had brought with him.             
          When the revenue agents realized that petitioner did not intend             

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Last modified: May 25, 2011