David J. Edwards - Page 8




                                        - 8 -                                         
          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                       








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011