- 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 of
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011