- 10 -
Apparently, the root of petitioner’s disagreement with the
returns is his dispute with certain record companies over
royalties. Petitioner has tried to involve respondent in that
dispute by asking respondent to subpoena information from the
record companies so that he could make what he believes would be
more accurate returns. Respondent claims that neither section
6330 nor any other provision of the Internal Revenue Code
authorizes the IRS to aid petitioner as he has requested and
there is no evidence that Congress intended taxpayers to use
section 6330 to redress grievances against third parties.
Respondent further claims that petitioner presented no evidence
of the proper amount of royalties due him, nor any evidence
supporting his claim that the record companies violated his
copyrights or that he even has copyrights to any songs.
Petitioner, in his opposition to the motion, does not contradict
any of those assertions.
Petitioner may well have a dispute with the record
companies, and the returns may or may not be accurate, but
petitioner has placed nothing before us regarding the underlying
liabilities that we can properly adjudicate. Like the taxpayers
in Horn v. Commissioner, T.C. Memo. 2002-207, and Smith v.
Commissioner, T.C. Memo. 2002-59, whose efforts to dispute their
“self-assessed” liabilities we rejected, petitioner was not
prepared to allege and prove the facts showing his returns were
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011