James D. and Rita K. Snyder - Page 30




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          Memo. 1991-274, affd. 960 F.2d 1053 (8th Cir. 1992); Vnuk v.                
          Commissioner, T.C. Memo. 1979-164, affd. 621 F.2d 1318 (8th Cir.            
          1980).  Following are our grounds for imposing a penalty on                 
          petitioners under section 6673(a)(1).                                       
                    2.  The Petition                                                  
               Petitioners’ assignments of error include the following:               
          Respondent’s failures to show (1) “documented authority to impose           
          a tax liability”, (2) the “legal authority to impose a tax                  
          liability”, and (4) “the authority source for the imposition of a           
          legal tax obligation upon revenue sources from within the United            
          States”.  Petitioners’ averments in support of their assignments            
          of error include the following:                                             
               The Notice of Deficiency is required by Internal                       
               Revenue Code to be signed by a duly appointed                          
               assessment officer.  There is nothing indicated on                     
               form 4549-A, which is an attachment to the Notice of                   
               Deficiency that clearly defines that a duly authorized                 
               signature is present as required by the Internal                       
               Revenue Code sec. 6201, nor are any of the forms in                    
               compliance to 26 USC � 6065.                                           
               Petitioner, on information and belief, alleges that the                
               sole purpose of respondent’s Notice of Deficiency is                   
               for the obvious purpose of ensnaring the petitioner                    
               into a fraudulently obtained Federal Tax Court                         
               jurisdiction.                                                          
               On the provision that this petitioner is properly                      
               documented in the Trust’s “Individual Master File”                     
               (IMF), this Trust’s source of revenue is from within                   
               the United States and does not conform to any federally                
               regulated “taxable objects”.                                           
               Petitioner, on information and belief, disputes the                    
               “statutory grouping of gross income and the residual                   
               grouping of gross income” as it may relate to this                     
               matter pursuant to 26 CFR � 1.861-8(a)(4).                             




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