Chester H. and Michelle R. Rossman - Page 13

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          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.                                                                      







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