David M. Leggett - Page 18

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          petitioner and Ms. Leggett with respect to the civil penalties              
          that respondent had assessed around January 1994, petitioner                
          wrote a letter to the Service's District Director in Jackson-               
          ville, Florida, which stated in pertinent part:                             
               It has come to my attention that your thugs/agents                     
               locally have been making their rounds to local Natural                 
               Free Citizens to extort money from them, and to steal                  
               their property.  The returns that you refer to in your                 
               4/18/94 data have been Lawfully revoked as of 4/20/93                  
               (Lawful Affidavit) and corrected Lawfully.  My 4/29/94                 
               NOTICE OF OBJECTION, NOTICE TO ABATE (enclosed) still                  
               stands.  Any action on or against my property will be                  
               deemed as Fraud and WILLFUL TRESPASS.                                  
          By way of further illustration, when petitioner met with re-                
          spondent's agents at the September 1995 meeting, he made friv-              
          olous arguments about why he was not required to file returns,              
          questioned the authority of the Service over him, and refused to            
          provide the information that those agents requested in an effort            
          to determine his tax liability or otherwise to cooperate with               
          respondent's representatives.  At the March 1996 meeting that               
          petitioner had with the revenue officer, petitioner asked him to            
          specify the sections in the Code and the regulations that re-               
          quired him to file returns.  The revenue officer pointed out to             
          petitioner that the notice issued by the Service, which peti-               
          tioner had brought with him to the March 1996 meeting, informed             
          taxpayers that sections 6011 and 6012 required taxpayers to file            
          returns.  Nonetheless, petitioner never filed returns for the               
          years at issue.                                                             

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