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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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