David J. Edwards - Page 46




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          in writing to his frivolous and improper questions.                         
               Petitioner’s contention that Scar v. Commissioner, 814 F.2d            
          1363 (9th Cir. 1987), supports his argument is dead wrong.                  
          Petitioner’s argument that the notice of deficiency is invalid              
          because respondent did not make additional efforts to verify                
          petitioner’s claimed deductions after petitioner refused to                 
          substantiate them is frivolous and groundless within the meaning            
          of section 6673(a)(1)(B).                                                   
               The “Agency” Issue                                                     
               Petitioner has devoted 3 pages of his 12-page reply brief to           
          arguing that the Internal Revenue Service is not an “agency of              
          the United States”.  Presumably, petitioner intends by this                 
          argument to suggest that respondent has no authority to determine           
          or collect petitioner’s income tax deficiencies.                            
               In support of his argument, petitioner quotes a footnote               
          from the Supreme Court’s opinion in Chrysler Corp. v. Brown, 441            
          U.S. at 297 n.23 (1979), a single page of an answer to a                    
          complaint allegedly filed by the United States in an Idaho                  
          District Court case entitled Diversified Metal Prods., Inc. v. T-           
          Bow Co. Trust, 78 AFTR 2d 5830, 96-2 USTC par. 50,437 (D. Idaho             
          1996), citing at note 3 Blackmar v. Guerre, 342 U.S. 512, 514               
          (1952).                                                                     
               Petitioner’s argument is tax protester gibberish.  It’s bad            
          enough when ignorant and gullible or disingenuous taxpayers utter           







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