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assignments of error committed by respondent in determining the
deficiencies and additions in dispute and the facts on which he
based the assignments of error. Because petitioner filed amended
petitions that alleged, among other things, assignments of error
and facts that can be interpreted as raising justiciable issues,
respondent's motions were denied.
At trial, however, petitioner raised only one issue. That
issue can be distilled to a peculiar concept, often espoused by
tax protesters. He did not have income in the years at issue, he
said, because the corporate payroll checks he received were
debts, "And when you take that check to the bank, you get more
debts that are called" Federal reserve notes. Petitioner
admitted that he received the checks from various payers and that
he failed to file Federal income tax returns and pay taxes.
During the years at issue, petitioner was an insurance
salesman working on a commission basis for a number of insurance
companies. Before trial, petitioner refused to stipulate any
facts or exhibits. Respondent was forced to bring in from
various locations representatives from insurance companies to
testify concerning documents verifying their commission payments
to petitioner. Petitioner failed to question on cross-
examination any witness or raise an objection to the admission of
any of the documents they produced.
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Last modified: May 25, 2011