Dennis E. Runkle and Debra A. Runkle - Page 5

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          Petitioners paid approximately $1,000 to the American Institute             
          and wrote “untaxing service” in the memo section of the checks              
          and “final payment for untaxing.”                                           
               Petitioners did not file a Federal income tax return for any           
          year after 1990, nor have they made any estimated income tax                
          payments regarding those years with one lone exception.  Mr.                
          Runkle made a $1,987 payment towards his Federal income tax for             
          1991 on April 17, 1991.  Mr. Runkle made no payments for 12 years           
          until September 28, 2003, at which time he made separate $100               
          payments towards each of the years 1998, 1999, 2000, 2001, 2002,            
          and 2003.                                                                   
          American Institute’s Untaxing Service                                       
               Instead of filing tax returns and making payments,                     
          petitioners began sending correspondence typical of other                   
          “untaxing” programs to respondent’s Cincinnati Service Center in            
          March 1992.  Specifically, petitioners sent a letter dated March            
          24, 1992, in which they stated that they “hold the sincere belief           
          that the federal income tax laws do not apply to [them]” and they           
          “firmly believe that the IRS is operating under secret                      
          jurisdiction and, as such, is operating unlawfully.”  In a second           
          letter of the same date, petitioners stated that they recently              
          found that the IRS was operating under color of law and that the            
          IRS was attempting to extort money from them.  “This is a formal            
          demand that the [IRS] cease and desist from such activity at                

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