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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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