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oneself”. Petitioner failed to specify how any of these
privileges would apply to the financial records that formed the
basis for his returns.
Petitioner demanded written answers to his questions before
he would consider cooperating with respondent’s examination.
Petitioner demanded a written response stating: (1) The basis
for respondent’s examiner’s authority to conduct the examination;
(2) the statutory authority for the examination; (3) “you have to
show us where 7006 gets its implementing implant, excuse me,
implementing authority and if that implementing authority on 7602
is all inclusive to the outside of the definition”; and (4)
whether respondent could establish that petitioner had income
from one of the sources identified in section 1.861-8(f), Income
Tax Regs.
At the meeting, respondent’s examiner displayed her badge to
establish her authority to conduct the examination and cited
section 7602 to establish the statutory authority for the
examination. Respondent’s examiner advised petitioner both at
the meeting and in a letter dated February 10, 1999, that: (1)
Statutes are enforceable even if there are no regulations
interpreting them, and (2) section 1.861-8(f), Income Tax Regs.,
is irrelevant to petitioner’s returns and to the examination.
Petitioner did not produce his records in response to
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