Lou Deserio - Page 4

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               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                 

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Last modified: May 25, 2011