- 2 - discretion in sustaining the proposed collection actions and whether the Court should impose against petitioner a penalty under section 6673(a). FINDINGS OF FACT At the time he filed his petition, petitioner resided in Shreveport, Louisiana. Petitioner is an attorney admitted to practice before this Court. He has represented at least two taxpayers before the Court. See Olmos v. Commissioner, T.C. Memo. 2007-82; Heers v. Commissioner, T.C. Memo. 2007-10. Petitioner failed to timely file Federal income tax returns for 1995 through 2000 (years at issue). During the examination of the years at issue, petitioner submitted tax returns reporting all zeroes and attached documents entitled “Asseveration of Claimed Gross Income” and “Statement and Asseveration of Exclusion of Remuneration from Gross Income”. In the returns and attachments, petitioner argued that his income was not includable in gross income and raised various tax-protester arguments. After respondent received petitioner’s returns, respondent used the bank deposits method to reconstruct petitioner’s income.2 1(...continued) are rounded to the nearest dollar. 2 Respondent issued summonses to various banks, ordering the banks to produce petitioner’s bank records for the years at issue. Prior to the issuance of the notice of deficiency, (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007