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Petitioner’s challenge to the existence of his tax liability
is meritless. During the years at issue, petitioner earned a
significant amount of income as a doctor of veterinary medicine.
He filed tax returns for 1996 and 1997 that reported Schedule C
self-employment income of $59,077 for 1996 and $53,289 for 1997.
The tax assessments generating the filing of the Federal tax lien
are based on the tax shown on returns petitioner filed under
penalties of perjury. See sec. 6201(a)(1).
Despite respondent’s claim that petitioner could not
challenge his underlying tax liabilities for 1996 and 1997 as
reported on petitioner’s tax returns for those years, petitioner,
in fact, questioned the validity of those liabilities during his
telephone hearing. Petitioner advanced frivolous arguments
during this telephone hearing. Petitioner continued to advance
his groundless arguments in his petition, his trial memorandum,
and his trial testimony. Despite petitioner’s assertions to the
contrary, there is no genuine issue as to the existence of his
1996 and 1997 unpaid tax. And because petitioner challenged only
the existence of a law requiring him to pay a Federal tax on his
earnings and did not challenge the correctness of the amounts of
income which he reported on his 1996 and 1997 tax returns, there
is no genuine issue as to the amounts of petitioner’s underlying
tax liability for 1996 and/or 1997.
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Last modified: May 25, 2011