Michael Joseph Major - Page 10

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          E.   Petitioner’s Procedural and Constitutional Arguments                   
               Petitioner alleges various instances of misconduct by                  
          respondent’s employees during the audit of his 1999 and 2000                
          returns.  Petitioner contends that:  (1) Respondent improperly              
          increased the number of dependency exemptions that petitioner               
          reported on his 1999 return and then used the later denial of               
          those same dependency exemptions as a basis for initiating an               
          unlawful audit of petitioner’s 1999 return; (2) respondent                  
          improperly rejected petitioner’s offer in compromise; and (3)               
          respondent and the Court have illegally conspired to violate the            
          U.S. Constitution, RICO statutes, civil rights statutes, the IRS            
          Restructuring and Reform Act of 1998, the Internal Revenue Code,            
          the ABA Code of Professional Responsibility, and the Code of                
          Judicial Conduct.  We disagree.                                             
               There is no evidence supporting petitioner’s allegations.              
          Petitioner has not shown that respondent’s agents engaged in                
          unconstitutional or illegal conduct.  On his 1999 tax return,               
          petitioner listed his six children as dependents but claimed only           
          three personal exemptions.  Upon receiving petitioner’s 1999                
          return, respondent allowed petitioner the benefit of four                   
          additional dependency exemptions.  On audit, however, respondent            
          determined that petitioner was not entitled to dependency                   
          exemptions for three of the four children for whom he did not               
          claim exemptions on his 1999 return.  Respondent’s actions with             






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