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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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