- 13 - petitioner’s 1994 through 1996 tax returns. Petitioner contends it was prudent to learn whether his claimed deductions for 1994 through 1996 were allowable on the basis of the audit for these years before submitting tax returns for 1997 through 2000 on which he hoped to claim similar deductions. Tactically, he believed this could assist in his presentation of claimed deductions and avoidance of penalties. Petitioner argues that he made his 1994 through 1996 tax records available to Agent Riley, but the IRS nevertheless delayed in accepting petitioner’s claimed deductions for those years, and Agent Riley never told petitioner that many of his claimed deductions were eventually allowed by respondent. Consequently, he contended that he could not complete and file his 1997 through 2000 Federal income tax returns until March or April 2004. Petitioner believes that but for his health problems and time pressures due to the trial date he would have been able to substantiate more of his claimed expenses and further reduce his tax deficiencies. Petitioner denies any role in the delivery of a frivolous tax protester letter to the IRS. He maintains that his trust promotion and sales activity were directed at properly educating seminar participants regarding their tax obligations, thereby supporting the IRS’s tax law enforcement goals.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011