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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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