- 10 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011