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Burnett stated in the letter that he had “made several requests
in the past few years of the Internal Revenue Service, to clearly
state the law or Internal Revenue Code section which makes me one
who is made liable to pay any tax”. Mr. Burnett concluded in the
letter that he had yet to receive an answer from the Internal
Revenue Service as to his requests and that “Naturally, this has
led me to believe that there is no law or code section making me
liable to pay any tax.” The letter included as attachments:
(1) A 3-page May 7, 1996, letter written by Mr. Burnett and
addressed to the Commissioner in Washington, D.C. and (2) a 23-
page October 9, 1995, letter (accompanied by an 11-page
attachment) written by Mr. Burnett and addressed to the Internal
Revenue Service in Austin, Texas. Both letters contained
primarily tax protester rhetoric as to the validity of the
Federal income tax system. On April 22, 1998, the agent wrote
Ms. Burnett a letter offering to meet with her at a stated time
and place in order to determine her Federal income tax liability
for the relevant years. Ms. Burnett also refused to cooperate
with the agent.
Afterwards, following respondent’s expansion of the
examination to include 1997, respondent completed “dummy” returns
for petitioners that included their names, addresses, Social
Security numbers, filing status, and exemptions. These returns
did not include any amounts of income. Subsequently, on
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