Roy J. Chase - Page 7

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          any tax professionals on the legality of his position on taxes in           
          1987 through 1997.  He cites numerous cases out of context, while           
          ignoring those authorities contrary to his position.  He                    
          summarizes his position as follows:                                         
                    It is my understanding that I’ve never been made                  
               liable for a tax.  I don’t understand how one is made                  
               liable for a tax, but I have never received an                         
               assessment for any of the years in question.  Up until                 
               the notice of deficiency, I’ve never received any                      
               indication that the Government is asking me to pay                     
               money; that the IRS is asking me to pay money.                         
          Petitioner ignores the evidence concerning multiple notices to              
          him that he had failed to file required returns and the                     
          investigation of his liability for 1987 and 1988 that commenced             
          in 1991 and resulted in criminal prosecution.  Petitioner claims            
          that he won the criminal case and therefore believes that he was            
          correct.  He also claims that his beliefs were reinforced by the            
          length of time that it took the IRS to proceed against him                  
          civilly.  As is usual, however, civil proceedings awaited the               
          conclusion of the criminal matter.  See, e.g., Badaracco v.                 
          Commissioner, 464 U.S. 386, 399 (1984); Taylor v. Commissioner,             
          113 T.C. 206, 212 (1999), affd. 9 Fed. Appx. 700 (9th Cir. 2001).           
          The notices of deficiency followed promptly after dismissal of              
          the criminal case.                                                          
               Petitioner’s arguments concerning liability are stale and              
          have been uniformly rejected.  No further discussion of them is             
          warranted.  See Lonsdale v. United States, 919 F.2d 1440 (10th              






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