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At the hearing, petitioner denied the existence of the
notices of deficiency, notices and demand, and other pertinent
documents on the grounds that they were either not personally
signed by the Secretary of the Treasury or that they were not on
the official form. His arguments were without substance and
based on selective readings and interpretations of cases,
statutes, and related materials. He also confronted the Appeals
officer with a copy of the Internal Revenue Code and challenged
him to show where in that document petitioner was required to pay
any tax. Petitioner also asked whether he could delegate to the
Appeals officer a power of attorney, so that petitioner could
assign the responsibility of filing petitioner’s income tax
returns to the Appeals officer. Petitioner did not raise any
spousal defenses or collection alternatives at the hearing.
After the hearing, respondent issued notice of intent to proceed
with collection.
In documents that petitioner submitted to respondent he made
protester arguments; i.e., that he was not subject to the income
tax because he was an American citizen and that only nonresident
aliens and Federal employees are subject to Federal tax.
Petitioner also sent in materials concerning Irwin Shiff, a
reputed tax protester.
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Last modified: May 25, 2011