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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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