Robert Eugene Poindexter - Page 10

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               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             






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