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to the amended Form 1065 was Form 8275 including tax protester
rhetoric similar to that on Form 8275 attached to the return
filed by Miroyal in 2000.
During 1999 and 2000, National Land Bank had a bank account
at the San Tan Credit Union (Account No. 8198). Mr. Johnson
testified that petitioner controlled Account No. 8198 at the San
Tan Credit Union in the name of National Land Bank and authorized
all payments from this account in the name of National Land Bank.
2. Taxable Year 2000
On June 7, 2001, petitioner filed Form 1065 for 2000 on
behalf of National Land Bank showing no income. As in the
instance of the amended 1999 tax return, the attached Form 8275
contained tax protester rhetoric. In addition, a Form 4852,
Substitute for Form W-2, Wage and Tax Statement, or Form 1099-R,
Distributions From Pensions, Annuities, Retirement or Profit-
Sharing Plans, IRAs, Insurance Contracts, etc. (stating that
National Land Bank had, in petitioner’s opinion, been unable to
obtain a correct Form 1099, Miscellaneous Income, from its
employer, Circle G Property Development), accompanied National
Land Bank’s Form 1065 tax return for 2000.
8(...continued)
Trust are one and the same entity and shall hereafter refer to
both as “Speck”. Despite the amended 1999 Federal income tax
returns for petitioner and National Land Bank, respondent audited
the original returns, and the audit adjustments are keyed to
those returns as is our report in this case.
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