Randy A. Belmont - Page 2

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          review of respondent’s determination.  The sole issue for                   
          decision is whether respondent’s determination that collection              
          action could proceed for Federal income tax liabilities for 1999            
          was an abuse of his discretion.                                             
                                  FINDINGS OF FACT                                    
               The parties’ stipulation of facts and attached exhibits are            
          incorporated herein by this reference.  Petitioner resided in               
          Lakewood, Ohio, when he filed his petition.                                 
               On April 15, 2000, petitioner and his wife, Christina L.               
          Belmont, filed a joint Form 1040, U.S. Individual Income Tax                
          Return, for 1999.  The Form 1040 showed zeros on lines 7 through            
          22, zero adjusted gross income (line 33), zeros on lines 36                 
          through 40, zeros on lines 48 through 56, zero total tax, Federal           
          income tax withholding in the amount of $839, and a claimed                 
          refund in the amount of $839.  Petitioner attached to the 1999              
          Form 1040 several pages of writing in which he stated he had zero           
          income within the meaning of that term, and included other                  
          frivolous tax-protester arguments, such as, the return was not              
          filed voluntarily, petitioner is not required to file a return,             
          petitioner’s earnings are not considered income under the                   
          Corporation Excise Tax Act of 1909, the assessment was illegal,             



               1(...continued)                                                        
          the Internal Revenue Code, as amended, and amounts are rounded to           
          the nearest dollar.                                                         





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