- 46 - 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 utterPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
Last modified: May 25, 2011