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settlement charges for property taxes because petitioner failed
to substantiate the expense, and respondent disallowed any
adjustments for the remaining items.
Petitioner’s Failure To File Income Tax Returns and Related
Correspondence
Petitioner failed to file Federal income tax returns for
1996, 1998, and 1999. On April 2, 1997, petitioner mailed an 11-
page letter to the Department of the Treasury in Washington,
D.C., requesting that it provide him with the “taxing statutes”
that impose on him any Federal income tax liability or require
him to file a Federal income tax return. The letter also
contained typical tax-protester arguments regarding the
constitutionality of the Federal tax laws and quotations from the
Code, Income Tax Regulations, and caselaw relating to the
authority of the Federal Government to impose an income tax. On
June 16, 1997, petitioner mailed the same letter requesting the
taxing statutes to the Internal Revenue Service’s (IRS) Ogden,
Utah, office.
On May 15, 2002, respondent sent petitioner a 30-day notice
stating that the IRS had not received petitioner’s 1999 Federal
income tax return. In the letter, respondent also proposed an
income tax deficiency and additions to tax for petitioner’s 1999
taxable year and advised petitioner of the Code sections that
required him to file a return and provide certain information to
the IRS. In response to respondent’s 30-day notice, on June 14,
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