Roy J. Chase - Page 6

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          Petitioner continued to maintain similar arguments through                  
          investigation of his liability for subsequent years, during a               
          criminal case brought against him, through trial of this                    
          proceeding in February 2004, and in his posttrial brief.  The               
          criminal case that was commenced against petitioner was dismissed           
          in 2001 when the presiding judge indicated that the matter should           
          be pursued civilly rather than criminally.                                  
               In 1998, petitioner and his wife incorporated a business as            
          Strategic Computer Solutions.  The corporation had employees,               
          including petitioner and his wife, and issued Forms W-2, Wage and           
          Tax Statement, at the end of each year.  Federal income taxes and           
          Social Security taxes on the employees, including petitioner and            
          his wife, were withheld, and the withheld taxes were paid to the            
          IRS.  Petitioner and his wife filed joint returns and reported              
          their wages for 1998 and subsequent years.                                  
                                       OPINION                                        
               Petitioner has not raised any nonfrivolous arguments                   
          concerning the amount of deficiencies determined in the statutory           
          notice.  He has asserted various arguments concerning procedural            
          matters and failures of the Government to prepare returns on his            
          behalf and to assess promptly the amounts owing.  He rejects the            
          Court’s explanation that assessment cannot occur until the                  
          decision in this case is final.  See sec. 6213(a).  He                      
          acknowledged during his testimony that he did not consult with              






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