The Tax Court yesterday in Pearson v. Commissioner, T.C. Memo. 2007-341 (11/19/07), rejected an invitation to deputize taxpayers to act as bounty hunters:
On May 24, 2006, respondent issued a notice of deficiency to petitioner for years 1999 through 2003, and petitioner timely petitioned this Court contesting respondent’s determinations. Petitioner strongly opposes the beliefs and actions of a particular organization (the Organization), and he asks that we allow him to audit the Organization and pay the taxes he owes out of the proceeds of that audit, even though petitioner’s tax liability is not related to the Organization. Petitioner has not filed Federal income tax returns for any year after 2003, and he does not intend to file voluntarily any returns or pay any tax until respondent takes some action against the Organization….
Petitioner asks that we allow him to audit the Organization, which is not a party to this case, and that he be able to pay his taxes out of the proceeds of that audit. There is no provision in the Code that gives us the authority to allow one taxpayer to audit another taxpayer in order to reduce his tax deficiency. Therefore, we deny petitioner’s request.
Joe Kristan fingers the unidentified organization.
Update: Jim Maule has more here.




