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Year Gross Receipts
1987 $41,011
1988 36,141
1989 22,866
1991 36,939
1992 101,159
1993 125,591
1994 64,118
1995 44,257
1996 84,656
1997 17,772
In addition, petitioner received minor amounts of interest income
during these years.
During the years in issue, petitioner accumulated cars,
boats, and motorcycles. In 1996, petitioner and his wife
purchased a home in Florida. The deed was recorded in the name
of petitioner’s wife.
In 1991, the Internal Revenue Service (IRS) commenced an
investigation of petitioner’s Federal income tax liability for
1987 and 1988. In a response to an administrative summons,
petitioner and his wife wrote a letter to the IRS that asserted
the following arguments:
We must, first of all, inform you that we have no
tax liability for the years in question. We must,
secondly, inform you that we possess a number of rights
and that we claim all of our rights at all times.
A question of jurisdiction arises in your claim
against us for the liability of any income tax. We are
now, and were during the years in question, citizens of
the State of New Hampshire. We do not now, and did not
during the years in question, work or reside in any
territory which is, or was, under exclusive federal
jurisdiction. We are not now, and have never been,
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