- 4 - Alternatively, it is determined that the attempted assignment of your income to Photo Art Marketing Enterprises Trust and/or Photo Art Publishing Trust is not recognized for Federal Income Tax purposes and that such income is taxable to you individually. Since 1992, petitioner has sent documents to respondent that contain statements and/or that take positions that do not address the substance and merits of respondent’s determination. Respondent has labeled petitioner’s arguments as frivolous. For example, petitioner has attempted to revoke his returns, or signatures thereon, that he had filed with the IRS. Petitioner has continually asserted that the IRS and its officers and agents have no authority over him, and on one occasion petitioner explained his position regarding his Fifth Amendment privilege vis-a-vis the income tax. Petitioner has continually refused to submit information to respondent regarding the trusts and a limited liability corporation. Petitioner’s tax proceeding has been pending in this Court since the December 28, 1998, filing of his petition. In that petition, petitioner alleges that this Court lacks subject matter jurisdiction over questions involving related trusts. Although petitioner’s expression of his position is somewhat elusive, his contention appears to be that respondent has no authority to make any determination with respect to petitioner’s trusts or other entities. Respondent has determined that petitioner’s trust and/or other entities are to be disregarded for purposes ofPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011