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the amount of $46 received from several payors.
On July 22, 1998, John B. Kotmair, Jr. (Mr. Kotmair) of
Westminster, Maryland, wrote a letter to respondent on behalf of
petitioner. In the letter, Mr. Kotmair stated that petitioner
had received the foregoing notice of deficiency, and that such
notice was invalid because it was not signed under penalties of
perjury and because it did not explain petitioner’s appeal
rights.
In August 1998, petitioner executed a document entitled
“PRIVACY ACT RELEASE FORM AND POWER OF ATTORNEY”, by which
petitioner granted Mr. Kotmair the authority to “represent,
inquire of and procure from the Internal Revenue Service any and
all of the records, pertaining to income taxes, * * * regarding
the following years: 1980 through and including 1998.”2 The
record indicates that Mr. Kotmair wrote two additional letters to
respondent on petitioner’s behalf. Petitioner did not file a
petition for redetermination with the Court challenging the
notice of deficiency.
On April 27, 2000, respondent filed with the Washoe County
Recorder in Reno, Nevada, a Form 668(Y), Notice of Federal Tax
2 The above-described “power of attorney” identified John
B. Kotmair, Jr., as a fiduciary for Save-A-Patriot Fellowship and
stated that petitioner was a member of the group. Save-A-Patriot
Fellowship has been identified as an organization that is opposed
to the Federal income tax. See Save-A-Patriot Fellowship v.
United States, 962 F. Supp. 695 (D. Md. 1996).
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