Jan Lister - Page 12

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                    1.  Petitioner’s Underlying Tax Liabilities                       
          for 1993-94                                                                 
               In her original petition and in her amended petition,                  
          petitioner has asserted various arguments, most of which are                
          confused and sometimes unintelligible.  As best we understand               
          them, however, the arguments appear to be directed to the                   
          existence of the underlying tax liabilities for 1993 and 1994 and           
          are summarized below:                                                       
               a.  Petitioner never received wages because wagering on the            
          job is illegal.                                                             
               b.  Petitioner did not receive any payments in cash or                 
          property; she received only Federal Reserve notes, which are not            
          cash, property, or assets of any kind.                                      
               c.  The U.S. Government owes petitioner money in the form of           
          allowances and credits to which she is entitled which the                   
          Government has failed and refused to pay.                                   
          Each of the above-described arguments challenges the existence or           
          amount of the underlying tax liabilities for 1993 and 1994.  See            
          sec. 6330(c)(2)(B).                                                         
               The undisputed facts in this case establish that petitioner            
          received a notice of deficiency for each of the years 1993 and              
          1994.  Petitioner did not file any petition in this Court seeking           
          a redetermination of the proposed deficiencies.  As a result,               
          upon the expiration of the statutory restriction on assessment              

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