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That attorney was Mr. Sulla (who, as stated, entered his
appearance on June 21, 2000). In a subsequent telephone
conference among Judge Marvel, Mr. Sulla, and respondent’s
counsel, Judge Marvel advised Mr. Sulla that, if petitioner
continued to present frivolous arguments, the Court would impose
penalties. The Court further advised Mr. Sulla that he bore the
responsibility to straighten his client out. Petitioner’s
request for a continuance was granted.
By letter to respondent’s counsel dated September 12, 2000,
Mr. Sulla reviewed petitioner’s arguments as to why he did not
owe income tax for 1996. Those arguments include the following:
(1) Petitioner had no income from any source taxable under the
Internal Revenue Code; (2) no provision of the Internal Revenue
Code obligates petitioner to file a Form 1040, U.S. Individual
Income Tax Return, and, therefore, payment of the Federal income
tax is voluntary, and (3) the Form 1040 provided by the Internal
Revenue Service is a “bootleg” request because it does not
conform to the requirements of the Paperwork Reduction Act of
1980, as amended, in that the form does not display a control
number, an expiration date, or a statement whether the form is
voluntary or mandatory. Mr. Sulla did not disavow those
positions, but asked of respondent’s counsel: “Any responses or
interpretations, supported by authorities, which you would assert
in opposition to the positions taken by [petitioner]”.
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