UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Sheri Reed Patriot )
Warren T. Patriot )
Stephen Reed )
Lauren Reed }
Petitioner(s) } CASE # 2:06-cv-002
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V. }
United States of America } INTERROGATORIES
SunTrust Bank }
The Bank of New York )
Bank of America )
Old Florida Bank }
Respondent(s) }
Pursuant to Rule 33 of the FRC1vP, this set of Petitioner’s Interrogatories is propounded to the
As used herein, the term “identify” with reference to an individual means to furnish his full name, job title, job description, address, and relation to this action. With reference to a document, “identify” means to state its title, its nature, its date, its author and addressee, its location, its description, and its custodian.
1. Is the Tax protest Coordinator for the IRS in this district involved with this case? Explain in detail the nature and scope of his/her involvement.
2. Have you read Manual Supplement 9G—93 or any other procedural guidelines on “Tax Protest-type Activities”?
3. Explain the criteria or standards used by the IRS in “Protest—type cases” to recommend criminal prosecution to the Department of Justice. What percentage of cases classified as “Tax Protest” cases are so recommended?
4. Explain the criteria or standards used by the Department of Justice to decide to prosecute “tax protest—type” cases. What percentage of cases classified or identified by IRS as “tax protest” are prosecuted?
5. How many American citizens in this IRS district have been classified/identified as “Tax protestors”? How many in this region? Nationwide?
6. Define a) “Flagrant tax protestors,” b) “tax protest leader,” C) “flagrant noncompliance situation.”
7. Explain the IRS criteria or classification scheme for making such identifications as “tax protest leader” or “flagrant tax protestors.” Explain the DOJ’s criteria or identification scheme for such.
8. How many persons classified as “tax protestor” have been also classified as “flagrant tax protestor” or “tax protestor leader”? What percentage of “tax protestors” are also identified as “flagrant tax protestors”?
9. What percentage of “tax protest leaders or “flagrant tax protestors” are recommended by the IRS to the DOJ for prosecution? What percentage of them is prosecuted?
10. Have any “tax protestors” received routine civil audits by IRS in this district and region and nationally? What are the percentages?
11. Have any routine civil audits involved summons under IRS §7609?
12. What percentage of “tax protestors” whose investigation involved third-party summons was later recommended for prosecution?
13. Has the Regional Commissioner for this IRS region been informed of this investigation or the issuance of the summons in this case? If so, when? In writing? Did the Regional Commissioner respond? If so, when? In writing?
14. What authorities or manuals define a “tax protestor” or the procedures pertaining to a “tax protest return”?
15. What officials have authority to classify citizens as a “tax protestor”?
16. Has Petitioner(s) been classified as a “tax protester”? If so, by whom? If so, why?
17. Was this a blanket classification, or done individually based on a personal examination of Petitioner(s).
18. During the course of this investigation of Petitioner(s), has any IRS agent read Petitioner(s) his “Miranda rights?” If so, is this a normal procedure for a civil investigation?
19. What caused this investigation to begin? Was Petitioner’s tax return identified at the
20. Was this case assigned to the investigators in writing? If so, identify the assignment form.
21. Have any reports or memoranda been made by the IRS on or concerning Petitioner(s)?
22. Are any of the documents or information sought by the summons already in possession of the IRS? If so, identify those documents.
23. Explain the relevance or purpose of each document sought to any lawful purpose of the IRS and explain the purpose.
These Interrogatories are continuing in nature and additional information should be furnished when you receive it.
Certificate of Service: We do hereby certify that on this date, we sent properly a copy of the above to the parties listed on the attached Service List by depositing a copy thereof, postage prepaid, in the
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Sheri Reed Patriot, Petitioner, Pro se
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Warren T. Patriot, Petitioner, Pro se
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Stephen Reed, Petitioner, Pro se
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Lauren Reed, Petitioner, Pro se
Petitioner Address: