Laura K. Davis, et al. - Page 5




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          penalty of $25,000 upon him under section 6673(a)(1) for                    
          instituting the case for purposes of delay and for making                   
          frivolous arguments.2  Mr. Davis did not appeal the order and               
          decision.  Respondent timely assessed the 1997 and 1998                     
          deficiencies and other amounts on August 1, 2001 (Ms. Davis, for            




               2  In support of our order and decision, we relied on the              
          following deemed admissions (paragraph numbers and ellipses                 
          omitted):                                                                   
                    Petitioner Jeffrey W. Davis created a series of                   
               sham trusts designed to assist him in evading the                      
               payment of his Federal income and employment taxes.                    
                    Petitioner Jeffrey W. Davis created the JLD Asset                 
               Management Trust to avoid paying his Federal taxes.                    
                    The JLD Asset Management Trust is a sham trust.                   
                    The Davis Charitable Trust is a sham trust.                       
                    The petitioner Jeffrey W. Davis instituted this                   
               case to delay the assessment of his individual income                  
               taxes for the taxable years 1997 and 1998.                             
                    The petitioner Jeffrey W. Davis instituted this                   
               case to use the Tax Court as a forum to present                        
               frivolous constitutional and procedural arguments                      
               against the United States’ Federal income tax system.                  
                    The petitioner Jeffrey W. Davis fired his                         
               attorney, Scott W. Gross, after Mr. Gross refused to                   
               file frivolous motions in connection with this case.                   
                    The petitioner Jeffrey W. Davis intentionally,                    
               recklessly and negligently disregarded the Federal tax                 
               laws in the preparation of his 1997 and 1998 Federal                   
               income tax returns.                                                    







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