Paula M. Olsen - Page 5

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          Judgment, claiming that she did not have a "taxable source of               
          income"; therefore, she owed no Federal income taxes.  Such                 
          arguments and positions have been raised before in countless                
          numbers of cases and have been dismissed summarily as tax                   
          protester arguments.  Petitioner's motion was denied.  At trial,            
          petitioner presented no evidence to dispute the income payments             
          to her during the years in question, nor did she present any                
          evidence to increase the itemized deductions conceded by                    
          respondent.  Her sole position was to have the attorney for                 
          respondent removed from her case, and, in lieu of that,                     
          petitioner testified: "So then why don't we just do this: Let's             
          make it very simple.  Why don't you just rule against me and I'll           
          take it to appeal and I'll get rid of him somewhere along the               
          line there."  No motions were filed by petitioner to have the               
          attorney recused from the case.  Following the trial, the Court             
          ordered the parties to file memoranda.  The memorandum filed by             
          petitioner was another motion for summary judgment on the same              
          grounds as the previous motion that was denied.  This posttrial             
          motion was also denied.                                                     
               Petitioner's arguments, as outlined above in her "statement"           
          and "declaration" in lieu of tax returns and in her two motions             
          for summary judgment, are tax protester arguments that have been            
          heard on numerous occasions by this Court, as well as other                 
          courts, and have been consistently rejected.  The Court sees no             

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