Peter T. Storaasli - Page 13

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          inappropriate, and a waste of time, and that we would consider              
          any such arguments in deciding the motion to impose sanctions               
          under section 6673.                                                         
               Following the trial, we directed the parties to prepare and            
          submit a supplemental stipulation of facts and to address the               
          application of section 1034.  Although the supplemental                     
          stipulation of facts makes no mention of section 1034, and                  
          neither party made any arguments regarding section 1034 in their            
          posttrial memoranda, we address the effect of section 1034 on               
          petitioner’s sale of property in the opinion that follows because           
          section 1034 affects the computation of gain from the sale of               
          petitioner’s Rose Point Lane property.                                      
               On June 28, 2004, petitioner’s posttrial memorandum was                
          filed.  In the posttrial memorandum, petitioner argued that                 
          “respondent has refused at all times verbally or upon documents             
          to set forth any laws which authorizes [sic] him to take the                
          actions or make claims for his process of income tax assessments”           
          and that “it is self evident that nothing within the language of            
          the respondent’s Supplemental Stipulations of Facts is based upon           
          any United States tax law, statutes or regulations.”  Petitioner            
          also continued to advance arguments regarding the tax treatment             
          of personal labor in his posttrial memorandum.  On July 28, 2004,           
          we filed petitioner’s answering posttrial memorandum, which                 
          contained 27 pages of tax-protester arguments similar to those              






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