William M. Leggett - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WHERRY, Judge:  This case is before the Court on a petition            
          for judicial review of a Notice of Determination Concerning                 
          Collection Action(s) Under Section 6320 and/or 6330.  The issues            
          for decision are:  (1) Whether respondent may proceed with                  
          collection by levy of petitioner’s tax liabilities for the 1994,            
          1995, and 1996 taxable years; and (2) whether the Court should              
          impose a penalty pursuant to section 6673(a).1                              
                                  FINDINGS OF FACT                                    
               At the time the petition was filed, petitioner resided in              
          Sorrento, Florida.                                                          
               Petitioner failed to file Federal income tax returns for his           
          1994, 1995, and 1996 taxable years.  On July 26, 2000, respondent           
          mailed to petitioner a notice of deficiency for those taxable               
          years.  Petitioner timely petitioned this Court, and a trial was            
          held on October 15, 2001 (2001 trial).  At trial, petitioner                
          argued that the exchange of his personal physical services for              
          Federal Reserve Notes did not constitute taxable income.  The               
          Court issued an Oral Findings of Fact and Opinion which sustained           
          the deficiencies and additions to tax determined by respondent              
          and admonished petitioner for failing to file his returns and               
          raising frivolous tax-protester arguments.                                  


               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code (Code) of 1986, as amended.                       




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