Charles H. Little III - Page 5

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          wife assumed custody of the other girl, whom they later adopted.            
          That child was born in 1992 and for several years had serious               
          medical problems, all of which were costly to petitioner and his            
          wife.  Petitioner contends that these events had a severe impact            
          on him and his wife.  The Court understands that to mean that               
          petitioner and his wife essentially lost focus on their lives.              
          At some point, petitioner heeded the advice of a lady who                   
          encouraged people not to pay Federal income taxes, and he filed             
          protester income tax returns based on that advice.  As an                   
          example, for the 1997 tax year, petitioner and his wife filed a             
          joint Federal income tax return on which they reported their                
          income, expenses, and a tax liability of $6,395.  Based on the              
          advice of the return preparer, petitioner thereafter filed three            
          amended returns claiming an overpayment on each amended return.             
          The claimed overpayment on the third return constituted the                 
          balance of tax reported on the original return.  During all this            
          time, petitioner continued in his regular employment.  Petitioner           
          was also courted during this time by other professional tax                 
          protesters who charged for their advice on how to beat the tax              
          system.  At some point, some of petitioner’s peers in the real              
          estate business counseled him that professional protesters were             
          “crooks” who would take his money, and, ultimately, he                      
          (petitioner) would be held liable for his taxes.  Petitioner                
          accepted this advice and decided to thereafter file Federal                 

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