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$190,791, and $166,208, respectively. Petitioner failed to file
timely Federal income tax returns or pay taxes due for his
taxable years 1983 through 1987.
Petitioner was convicted of and incarcerated for willful
failure to file Federal income tax returns for 1986 and 1987.
Petitioner’s supervised release from prison was revoked because
of his continuing failure to file returns in accord with an order
of the U.S. District Court for the District of Kansas.
Beginning in 1980, petitioner used as his bank the National
Commodity Exchange, operated by Larry Dale Martin to hide his
financial transactions from the Internal Revenue Service.3 In
addition, petitioner failed to maintain complete and accurate
3 Larry Dale Martin has been described as “a ‘banker’ for
tax protesters” as follows:
Under the name of the National Commodity Exchange * * *
[Larry Dale] Martin offered to buy gold and silver
coins and bullion for the accounts of persons
distrustful of Federal Reserve notes and desiring
maximum privacy in their financial dealings, and also
to convert gold and silver in the depositors’ accounts
into paper money and at the depositor’s direction pay
his bills with the paper money. The agreements with
the depositors stated that in buying gold and silver
for their accounts and in paying their bills Martin was
‘acting only as an agent for the above specific
purpose[s] and no other.’ The agreements also contained
Martin’s pledge not to divulge any information about
the agency accounts.
Commissioner v. Hendrickson, 873 F.2d 1018, 1021-1022 (7th Cir.
1989), revg. and remanding T.C. Memo. 1983-560. Several opinions
contain conclusions and/or findings that the National Commodity
Exchange’s purpose included the above-described privacy and
“banking” services without a paper trail. See, e.g., Grandbouche
v. Commissioner, 99 T.C. 604, 606-607 (1992).
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