- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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