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This Court has held that the authoritative sources of
Federal tax law are statutes, regulations, and published court
opinions, not informal IRS sources such as telephone
conversations with IRS employees. See Zimmerman v. Commissioner,
71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d
1294 (2d Cir. 1979); Green v. Commissioner, 59 T.C. 456, 458
(1972). Furthermore, to promote uniform application of the tax
law, “the Commissioner must follow authoritative sources of
Federal tax law and may correct mistakes of law made by IRS
agents or employees.” Deal v. Commissioner, T.C. Memo. 1999-352
(citing Dixon v. United States, 381 U.S. 68, 72 (1965); Massaglia
v. Commissioner, 286 F.2d 258, 262 (10th Cir. 1961), affg. 33
T.C. 379 (1959)).
Petitioner testified that IRS employees have threatened
“that they could come take my vehicle.” Petitioner maintains
that the treatment afforded her by the IRS is unacceptable and
inexcusable. Furthermore, she maintains that she doesn’t “think
it's right that * * * a person honestly trying to pay their taxes
should go through something like this with the IRS.” Petitioner
also maintains that if the outcome of this proceeding is not in
her favor she is unable to “pay this money back right now.”
While we are sympathetic to petitioner’s plight, the record
indicates that she was aware of potential problems with her tax
return, so much so that she was hesitant to rely on the
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Last modified: May 25, 2011