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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...)
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Last modified: November 10, 2007