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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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