Peter T. Storaasli - Page 11

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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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