-2-
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
For purposes of the instant cross-motions for summary
judgment, and the respective objections thereto, the record
consists primarily of documents set forth in respondent’s
administrative file, the pleadings filed herein, and the parties’
cross-motions for summary judgment and attachments thereto.
Background
Respondent seeks to levy on petitioner’s property in
connection with assessed and outstanding 1995, 1996, and 1997
Federal income taxes and additions to tax and interest in the
cumulative total amount of $520,099.
Petitioner apparently has a college degree from the
Midwestern Baptist College located in Pontiac, Michigan, with a
major in religious education. Petitioner has established a
purported religious ministry under the name of Creation Science
Evangelism, based in Pensacola, Florida.
Allegedly as part of his ministry, petitioner produces and
sells books and recordings and travels extensively throughout the
United States and occasionally in other countries giving
speeches. Petitioner also hosts a daily radio talk show and has
established Dinosaur Adventure Land, which is described as a
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Last modified: May 25, 2011