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Respondent’s revenue agent then asked whether petitioner had
brought any personal records to support his return. In response,
petitioner read a lengthy prepared statement objecting that it
was improper for respondent to audit more than 1 year’s return at
a time. He declared he would not provide any records until
respondent, in writing, answered certain questions, and even then
he would produce only those documents that would not “violate my
fourth amendment rights which guarantee the right to privacy of
one’s house, papers, effects and my fifth amendment right which
guaranties that one cannot be compelled to be a witness against
oneself”. Petitioner failed to specify how any of these
privileges would apply to the financial records that formed the
basis for his returns.
Petitioner demanded written answers to his questions before
he would consider cooperating with respondent’s examination.
Petitioner demanded answers in writing to the following
questions: (1) The basis for respondent’s examiner’s authority
to conduct the examination; (2) the statutory authority for the
examination; (3) “you have to show us where 7006 gets its
implementing implant, excuse me, implementing authority and if
that implementing authority on 7602 is all inclusive to the
outside of the definition”; and (4) whether respondent could
establish that petitioner had income from one of the sources
identified in section 1.861-8(f), Income Tax Regs.
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Last modified: May 25, 2011