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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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