Paul F. and Eleanore M. Nichols - Page 6




                                         -6-                                          
               copy of such an assessment, there is NO assessment,                    
               there is NO tax liability, and you DO NOT have the                     
               authority by any IR Code section to examine or                         
               investigate our tax return.                                            
               *       *       *       *       *       *       *                      
               Any further correspondence from you should be signed                   
               according to that code section, or you will be in                      
               violation of IRS Code section 7214(a)(7).  If we do not                
               have a reply from you within 60 days, we will consider                 
               this matter dropped.                                                   
               On July 14, 2000, petitioners mailed to respondent another             
          letter, Statement of Protest.  The letter stated:                           
               Let this letter serve as a written protest that we do                  
               not agree with any of the adjustments shown in IRS Form                
               4549-CG, Income Tax Examination Changes * * *                          
               *       *       *       *       *       *       *                      
                    As to Form 4549, Income Tax Examination Changes.                  
               Please be advised that we disagree with the examination                
               report in all aspects, and will not accept it as an                    
               [sic] lawful official documents.  If the examiners                     
               report is a lawful official document, then the examiner                
               failed to sign the report under penalty of perjury, as                 
               per IRC Section 6065.                                                  
               *       *       *       *       *       *       *                      
               Where is the taxing statute that congress mandates you                 
               identify as to any tax liability that we may have?                     
                                       OPINION                                        
               By notice of deficiency dated March 19, 2001, respondent               
          determined that the trusts were shams and should be ignored for             
          tax purposes.  Accordingly, respondent determined, petitioners              
          underreported their taxable income by the amount of income                  








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