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returns for the years beginning in 1987.7 There were, however,
existing assessed tax liabilities for the taxable years 1987
through 1992 arising from substitutes for tax returns prepared by
the Internal Revenue Service (IRS). In 1997, Agent Riley
contacted petitioner via letter, informing petitioner that he had
not filed Federal income tax returns for the 1994 through 1996
taxable years and requesting that petitioner submit returns for
those years to him.
Petitioner did not immediately reply to Agent Riley’s
request. When petitioner later responded to Agent Riley,
he stated that he would meet with his accountant and would submit
returns for 1994 through 1996 sometime in early 1998. During
this time, petitioner continued to conduct trust training
seminars advising people about their tax obligations. Agent
Riley received letters from petitioner every 30 days promising
returns within the next 30 days or so. However, petitioner did
not submit returns to Agent Riley during 1998, contending that he
was “still studying it out”.
While waiting for petitioner to submit returns, Agent Riley
received a letter dated November 17, 1998, signed by both
petitioner and Edward G. Marshall (Mr. Marshall), the attorney
representing petitioner in this case. The letter titled “Opinion
Letter” propounded arguments against the filing requirement and
7 Ultimately, petitioner filed Forms 1040, U.S. Individual
Income Tax Return, for 1994 through 1996 on May 11, 2000.
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