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insists that he has submitted to respondent declarations of
estimated tax, which should be presented to the Secretary of
Transportation for payment, which would discharge petitioner’s
tax liability. Petitioner’s argument is a frivolous tax-
protester argument. In addition, petitioner adopted tactics at
trial, such as initially refusing to state his name, that delayed
this proceeding. At the conclusion of the trial, at petitioner’s
request, the Court left the record open for any support of
petitioner’s legal position that he could provide. Petitioner
submitted a document entitled “Letter of Correction” (the letter
of correction) that we have filed as such. The letter of
correction claims: “An error was made by submitting a 1040ES
form and is therefore canceled by this letter of correction.”
Attached to the letter of correction is a copy of respondent’s
trial memorandum bearing repeated stampings by petitioner
stating:
Accepted for value $51,210.44. This property is Exempt
from Levy and account is prepaid.
Please adjust this account and release the proceeds;
products, accounts; and fixtures and release the order
or orders of the court to Me immediately.
Date February 16, 2001
Employer ID # 530149347
Endorsement [signed] Roy-Allen: Watson
Whatever credit we might give petitioner for the implied
concession in the letter of correction that petitioner owes tax
is negated by the attachment to that letter, which makes no
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