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Wednesday, April 23, 2008

The Jeopardy Assessment
 

THE JEOPARDY ASSESSMENT


           The IRS has the power to make a jeopardy assessment on individuals without notifying them as required by standard assessment procedures.  In order to make a jeopardy assessment, the IRS must think that the individual is attempting to hide assets from the government or that the individual is thinking of leaving the country with his assets.  Once the IRS begins the procedure, they can take all the assets they can find. However, the IRS must notify its victim in writing about the seizure and the individual does have the right to do an administrative appeal. He can file a suit in Federal Court to ask for a judge's evaluation of the jeopardy assessment if the IRS does not make a determination within 16 days.  Thirty days after the jeopardy assessment is performed, the IRS must issue a Statutory Notice of Deficiency.  If a Statutory Notice is not issued, the IRS cannot proceed and must return the property that they have taken.  If the individual files a Tax Court petition in response to the Statutory Notice, the IRS cannot sell any of the property until after a determination by the court as to the exact liability of the individual.



          Although jeopardy assessments are unusual, the IRS does have the power to jeopardy assess and they could do it to.  You must be sure to protest the assessment immediately and file a Tax Court petition when they issue a Statutory. Notice.  Good luck and keep on keeping on.


8:14 am est

Monday, April 7, 2008

The Charlatans of Freedom

THE CHARLATANS OF FREEDOM



            Probably the biggest problem in the Freedom Movement is the fact that there are many different individuals selling many different scams to enrich themselves.  Individuals in the Freedom Movement are easy pickings for con men because; there are many individuals who are only into the movement for the money.  They really have no interest in the philosophical elements of the Freedom Movement.


            For example, the worst mistake the Freedom Movement ever made was the use of Exempt W-4's.  If an individual has wages, he is not judgment proof.  Also the major reason for convictions in criminal cases is because of the filing of an exempt W-4 combined with the non-filing of a return.  In spite of the terrible record of the exempt W-4 approach, there are still individuals who recommend that approach.


            Recently I have received several calls telling me about a group in California that sells a sure-fire system to get the IRS off your back for $5,000.  I called up the leader of the organization and spoke with him.  Since I had to make an evaluation fast, I asked him several specific questions about tax law.  I asked him how he deals with a First Party Summons. He replied that he has a letter that people send out that makes the IRS go away.  Regarding Stat. Notices, he claimed that the IRS was not following procedures in issuing Stat. Notices; when I asked him to clarify; he went off on a long song and dance that showed he had absolutely no understanding of the true procedures that the IRS uses in the issuance of a Stat. Notice.


            This individual claims that he is able to remove levies and liens by writing letters to the IRS.  He also claims to have had several individuals removed from prison. When he was asked for proof, he said that he couldn't give that out.


            As a long time fighter in the Courts against the IRS and with hundreds of hours of experience in this arena, I am very skeptical about individuals who have silver bullets and then won't tell exactly what it is they do until after it is done. It is my opinion that the individual in California is either a con man or a fool or both.  The problem is, he won't have any problem finding fools to buy his product.  As PT Barnum once said; "A fool is born every minute."  In my estimation, in the Freedom Movement, five fools are born a minute.


            The main reason that criminal cases are lost in the Freedom Movement is because individuals do not pick a theory and stick to it.  They change and change and they become very easy targets for the United States Attorney who is no dummy on cross-examination. Some of the original ideas of the Freedom Movement were the best and they are the only ideas that we need.


            Let's analyze the issues and get some ideas about the issues that have merit and the issues that probably don't have much merit.



            1.  Wages are not income:  This is an old idea in the movement, but it has lost in all the courts of appeals.  If you raise the issue in Tax Court, you will get a $25,000 fine.  The only way this issue can be raised is in a refund suit or possibly in some sort of suit relating to denial of a technical conference.  An appeal from Tax Court might work but the cases are going to have to go to the Supreme Court. Attorney Jeff Dickstein has written an excellent book on this approach and I highly recommend it for individuals who like this issue. Basically, you shouldn't take this approach unless you are willing and able to take a good case to the Supreme Court. It is unlikely that the Supreme Court will hear this issue, however.


            2.  The Fifth Amendment.  This issue is tricky so you have to set it up right and there are still no guarantees; but it is the best issue that has ever been raised in the Freedom Movement.  The IRS claims that the Fifth Amendment is not an excuse for not filing a return and yet they continue to use information in criminal tax cases that individuals have given to them on 1040 returns.  If you wish to use this approach, you must develop your reason for having concern about waiving your Fifth Amendment Rights and you must seek opinions from professionals on the issue.  It is my opinion that this one issue with its related components is the most valid and worthwhile approach ever developed by the Movement and it is certainly a good enough issue to break the camel's back if we use it correctly.


            3.  Non resident alien stuff.  This issue has lost in the courts. It has been  the basis for more than  one criminal case that I know of.  It is my opinion that individuals who believe they are successfully using this approach are simply being "worked" by the IRS so they can be later hammered into submission in a criminal case.  I really don't think there is anyway that the government will ever succumb to this issue since it would involve such an incredible loss of power for them all over the board.  Furthermore, we do not need this issue; the Fifth Amendment issue is good enough.


            3.  The income tax is voluntary.  This is another great issue.  There is no statute that makes individuals liable.  The IRS Privacy Act Notice is unclear and does not follow the requirements of the Privacy Act.  If the Notice says anything, it says that you are not required to file returns, because it contains a Miranda type of warning.  The Notice says that the IRS can give all information they get to the Department of Justice obviously for use in a criminal tax case.  The IRS constantly refers to the income tax as voluntary in its publications and in the Internal Revenue Manual.  They do this because they wish to continue to use information proffered on 1040 returns in criminal tax cases. However, the IRS can assess individuals under Section 6020(b) who do not file returns and the IRS can proceed to collection.  Therefore, although filing tax returns is voluntary, if the IRS files one for you, they can then take their pound of flesh through levies, liens, seizures, etc.


            4.  Affidavits of rescission and revocation; quite frankly, I am sometimes embarrassed that I am involved in a movement with individuals who perform silly maneuvers like this one.  If there is no statue that makes you liable and you can't be required to waive your Fifth Amendment Rights, then why do you need to file affidavits of recession and revocation?  It has been my experience, and my experience is extensive on this issue that the IRS ignores these affidavits, and they make great evidence in criminal tax cases for the IRS.  Because of individual's constant changing of position, U.S. Attorneys are many times able to show bad faith to the jury.  Furthermore, these affidavits will not stop garnishments, levies, liens, etc; and anybody who tells you otherwise is not being truthful.


            5.  Quite frankly, there are no silver bullets.  Anyone who gets on the front lines must realize that he is taking a dangerous position.  You can't buy a packet for any amount that will protect you from the IRS or the Income Tax.  If it were that easy, I would have figured it out by now myself.  But in spite of that fact, there are still at least six groups that are selling silver bullets.  There is nothing except judgment proofing that can protect you from the IRS.  If you are an employee, you cannot do an exempt W-4, the IRS is going to get your money. However, that doesn't mean that you can't fight the IRS. There is very little danger either civilly or criminally if you choose to not file a return if the IRS has your tax money and counsel has advised you that you are NOT required to file.  If the IRS has your money without an assessment, you do have an issue; and you can have fun with it. It will be very difficult for the IRS to put you on the defensive.


            6.  If you are self-employed and you have absolutely no property, you have professional advice that you are not required to file returns, and you realize the possibility of a criminal conviction for a crime that you have not committed, then you might consider a front-line position.  You have to realize that even though you are right and even though you know you are right, a jury might still convict you and if you are not judgment proof, the IRS will be able to get your stuff.  The solution to the risks of an adversary position is to be the devil's advocate.  Look at your situation and decide what you will do if all your theories fail.  Assume the theories are going to fail and prepare for the worst.  It is better to be safe than sorry.  Taking a front line position against your spouse's wishes, or when you are an employee of a major corporation, can be very difficult if you do not think through the consequences and prepare for them.


            Remember this: There are no silver bullets.  There is nothing that some con man can sell you that will make the IRS simply go away and save your property. If you got into the front lines of the movement with property, you have already made your mistake, you may have to just take the hit and go on.  Many individuals, who have received silver bullet kits for large amounts of money, have really only succeeded in getting their civil case postponed while the IRS considers a criminal one. The con men selling these packages continue to sell them to the "true believers" in the movement who seem to want to be duped.  For your own protection, if you are offered a silver bullet; put the burden of proof on the con man.  Ask him to show you specific proof that the idea really works.  If the idea does work, you may be able to prove it by getting a complete FOIA file on the individual and finding out if the IRS really has stopped its procedures because of something that was said in a letter. The IRS could have simply turned the whole thing over to criminal investigation.  To date, I have never seen anyone come up with proof that is real proof.  For example, if the IRS sends you a letter removing a lien after you send them a letter, you cannot state absolutely that the lien was removed because of something you said in the letter; unless you do a great deal of research.

7:37 am est


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