- 12 -
time period payable to Nature’s Herb & Tea Garden which had been
deposited into the Norwest Bank Arizona, N.A. account titled,
“Sue Taylor d|b|a Natures’s Herb & Tea Garden”. Respondent also
provided copies of checks drawn on Nature’s Herb & Tea Garden’s
Norwest Bank Arizona, N.A. account and signed by petitioner, as
well as copies of the account’s bank statements reflecting Sue
Taylor DBA Nature’s Herb & Tea Garden.
OPINION
I. Contentions of the Parties
On the premise of tax protester arguments, petitioner
contends that she did not receive any taxable income for 1999 and
2000. She also maintains, among other things, that any income
received by any LLCs in which she was a member cannot be
attributed to her because respondent did not issue the LLCs a
final partnership administrative adjustment (FPAA) before issuing
the notice of deficiency. Further, petitioner states that even
if income in 1999 and 2000 can be attributed to her, she is
entitled to deductions, allowances, and credits that should have
reduced her tax liability to zero. Petitioner also asserts that
she should be entitled to recover her litigation and/or
administrative costs.9 Lastly, petitioner raises tax protester
9 Although petitioner claimed in her petition that she
should be entitled to recovery of her administrative or
litigation costs, she did not argue for costs at trial or on
brief. In any event, consideration of her eligibility for costs
(continued...)
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011