- 30 - 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).Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011