Chester H. and Michelle R. Rossman - Page 20

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               Taxpayers must file tax returns each and every year for                
          which gross income exceeds a certain threshold amount.  Sec.                
          6012(a)(1).  Each tax year represents a new liability and a                 
          separate cause of action.  Commissioner v. Sunnen, 333 U.S. 591,            
          598-599 (1948).  Petitioner is not entitled to use Agent Riley’s            
          investigation of previous tax years’ returns as an excuse for               
          failing to file current year returns.  Moreover, the Court does             
          not agree that petitioner’s alleged confusion as to whether to              
          file a Form 1040 or Form 2555 is a valid excuse to delay filing             
          either form.                                                                
               Petitioner believed NTS and FMG had promoted “a lot of very            
          big misconceptions to taxpayers”.  As a result, he claimed that             
          he started educating people about NTS’s and FMG’s fallacies and             
          misconceptions in 1992.  Despite petitioner’s asserted beliefs              
          regarding NTS’s and FMG’s promoted misconceptions, petitioner was           
          hired independently by NTS and FMG to conduct seminars sponsored            
          by them.  He also assisted in the formation of the NTS and FMG              
          promoted trusts.  Petitioner’s tax returns for 1997 through 2000            
          revealed that he continued to promote for profit abusive trust              
          schemes marketed by NTS and FMG through at least 2000.  The Court           
          finds petitioner’s testimony to be self-serving and contradicted            
          by his actions.  The Court deems petitioner’s reasons for failing           
          to file timely his tax returns to be manufactured and not                   
          a defense to fraud.                                                         






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