Christina L. Belmont - Page 8




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          Rewerts v. Commissioner, T.C. Memo. 2004-248; Jensen v.                     
          Commissioner, T.C. Memo. 2004-120.                                          
               Petitioner had complied with the tax laws by filing Federal            
          income tax returns in the 1990s.  When she was asked by                     
          respondent’s counsel on cross-examination whether she intended to           
          file all delinquent returns for 2000 forward, her answer was                
          evasive.  At the conclusion of the trial the Court asked whether            
          petitioner thought she was subject to the tax laws of the United            
          States.  Petitioner responded that she did not know; that the               
          income tax laws pertain to tobacco, firearms and liquor; and that           
          taxes were supposed to be done by apportionment.  She also                  
          testified, consistently with her August 2003 letter to the                  
          Department of the Treasury, that she wants a citation for the law           
          which makes her liable to pay Federal income tax.  Petitioner did           
          not cooperate with respondent to prepare this case for trial.               
               Petitioner’s actions evidence an intention to delay the                
          proceedings, and her arguments are frivolous and without merit.             
          It is truly unfortunate that she turned from being a taxpayer who           
          complies with the law into a tax protester.  However, petitioner            
          was not warned until the conclusion of the trial that a penalty             
          might be imposed under section 6673(a).  For this reason only, we           
          decline to impose a penalty under section 6673(a); but we                   
          strongly admonish petitioner that if she persists in failing to             
          file her income tax returns and in pursuing tax-protester                   







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