- 6 -
assessment and collection of taxes against petitioner for the 3
years at issue.
With respect to the adjustments in the notices of
deficiency, petitioner neither presented evidence nor provided
any testimony relating to respondent's adjustments for the 3
years in question. Petitioner's testimony dwelled on the letter
he received from respondent's Memphis, Tennessee, office stating
that he owed no taxes for 1995 and 1996. See supra note 3. In
addition, petitioner testified that he had "a lot of
constitutional questions that I can't raise here, which I've
asked to be raised in a District Court, which I've already filed
suit."5 However, petitioner did not deny receiving the amounts
paid to him that various payers reported to respondent.
Petitioner presented no testimony or documentary evidence to
substantiate the various itemized deductions and trade or
business expenses respondent disallowed for lack of
substantiation. Petitioner concluded his testimony with the
statement that his case rested on "constitutional questions I
want to raise up in the Federal District Court, and that will,
hopefully, include taxes that I may or may not owe." On brief,
petitioner argued the same constitutional objections, all of
5 In his brief, petitioner identified the case as docket
No. CV-S-00-535-LDG (RLH), Federal District Court, District of
Nevada, 9th District, in which he is claiming the U.S. Tax Court
has no jurisdiction over him.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011