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2002, petitioner mailed to the IRS’s Ogden, Utah, office another
copy of the 1997 letter requesting the taxing statutes. In
addition, petitioner mailed a 15-page letter dated June 14, 2002,
to the IRS’s Ogden, Utah, office requesting an administrative
appeal and reiterating his tax-protester arguments.
By letter dated November 6, 2002, respondent informed
petitioner that the U.S. Supreme Court has consistently held that
the Federal income tax laws are constitutional and that persons
who fail to comply with those laws may be subject to civil and
criminal penalties. In addition, respondent notified petitioner
of respondent’s intent to issue notices of deficiency for
petitioner’s 1996, 1998, and 1999 taxable years. On March 26,
2003, respondent issued three separate notices of deficiency for
petitioner’s 1996, 1998, and 1999 taxable years. Because
petitioner had not filed Federal income tax returns or produced
any basis documentation before respondent issued the notices of
deficiency, respondent computed the gain petitioner must
recognize on the sale of each property without allowing
petitioner any basis in the properties at issue.
Petitioner’s Conduct During Litigation
On June 24, 2003, the petition in this case was filed. In
the petition, petitioner contested the notices of deficiency for
1996, 1998, and 1999 and included several pages of typical tax-
protester arguments. On July 31, 2003, respondent filed a motion
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