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once.” Petitioners then sent an additional letter on May 27,
1993, to respondent’s Cincinnati Service Center advancing other
frivolous, tax-protester type arguments. In this letter,
petitioners declared that they were not taxpayers under the Code
and dismissed the sections cited by respondent as not being
“positive law.”
Petitioners did not conduct any independent research to
support the statements in petitioners’ letters to respondent.
Petitioners maintained contact with the American Institute
from March 1992 through at least 1995. In the course of
petitioners’ dealings with respondent, both administratively and
judicially, the American Institute provided petitioners with
rebuttal arguments to respondent’s positions.
Tax Planning Activities
Sometime between 1990 and 1993, Mr. Runkle met certified
public accountant William Boeykens (Mr. Boeykens) for what Mr.
Runkle characterized as “mainstream tax planning” using
partnerships, living trusts, and “pour-over” wills. Mr. Runkle
and Mr. Boeykens3 promoted and sold these partnership packages as
an income tax and estate tax planning program to their clients
during 1992 through 1995. Mr. Runkle used his knowledge of
3Mr. Boeykens advised Mr. Runkle that he was “crazy” for
becoming involved in the American Institute’s “untaxing service.”
Despite this advice, petitioners did nothing to “undo” their
involvement.
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