- 7 - 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 (10thPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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