Charles Raymond Wheeler - Page 4

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          taxable year 2001.  Petitioner timely filed a petition for this             
          year on April 30, 2004.  Both petitions disputed the deficiencies           
          and additions to tax and included lengthy tax protester                     
          arguments.  These cases were consolidated for purposes of trial,            
          briefing, and opinion.  At the time these petitions were filed,             
          petitioner resided in Colorado Springs, Colorado.                           
               At trial, respondent orally stipulated a decreased                     
          deficiency for 2001 of $2,336 and revised sections 6651(a)(1) and           
          6654(a) additions to tax of $389.50 and $58.83, respectively.               
          Petitioner agreed with these revised amounts.                               
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.                                      
          Petitioner’s Correspondences                                                
               Throughout the administrative process, the record reveals              
          that petitioner, as trustee of the Charles R. Wheeler Trust                 
          (trust) or in his individual capacity, sent at least three                  
          frivolous documents to respondent challenging his and the trust’s           
          obligation to file an income tax return and to pay income taxes.            
          Petitioner sent a letter dated November 8, 2000, to respondent’s            
          counsel in St. George, Utah, and the Internal Revenue Service               
          (IRS) Service Center in Ogden, Utah.  That letter concluded as              
          follows:                                                                    
               Having studied Title 26 and various IRS manuals and                    
               documents extensively, we have determined that the IRS                 





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