Petition for Writ of Certiorari — Johnson v. Commissioner

Supreme Court, U.S.

FILED

y

86-2059 JUN 22 1987

JOSEPH F. SPANIOL, JR.

CLERK

No. 86 a.

IN THE

Supreme Court of the United States

OCTOBER TERM, 1986

CARLYN M. AND CAROL J. JOHNSON

(C-Mr-J ENTERPRISES)

Appellants,

Ve

COMMISSIONER OF INTERNAL REVENUE

(INTERNAL REVENUE SERVICE)

Appellees.

PETITION FOR A WRIT OF CERTIORARI/

PETITION FOR A WRIT OF CERTIORARI

BEFORE JUDGMENT

TO THE UNITED STATES COURT OF APPEALS

FOR THE EIGHTH CIRCUIT

CARLYN M. AND CAROL J. JOHNSON

11987 Brookmont Drive

Maryland Heights, Missouri 63043

(314) 739-8326

Pro-Se

QUESTIONS PRESENTED

1. In the First Part of the Appellants Petition: Does the Civil Rights Act

of 1871 Section 1983 provide protection for the Appellants if and when: a.)

The IRS violates Code 446 § 4060 of the IRS Rules & Regulations in the

Federal Tax Guide Reports when the agent refuses to accept valid documents

provided by the Appellants; b.) The IRS violates Code 274 § 3592 of the

IRS Rules & Regulations in the Federal Tax Guide Reports when the agent

refuses to accept reasonable and probabie oral evidence to substantiate valid

deductions; c.) The IRS violates Code 6001 § 6561 of the IRS Rules &

Regulations in the Federal Tax Guide Reports when the Appellants have

never been issued an Administrative Summons from the agent or anyone

else from the IRS and the agent orders the Appellants to produce their books

for their business and inspects the books without an Administrative Sum-

mons. d.) The IRS violates § 15,019 - ‘Field Examinations of Returns’ of

the IRS Rules & Regulations in the Federal Tax Guide Reports by demanding

that the Appellants bring all their records, accounting books and everyting

pertaining to the business into their office (no matter how many boxes the

Appellants had to bring in) and refused to conduct the examinations year

after year at the Appellants place of business; e.) The IRS violates Article

7 - Amendment 4 of the U.S. Constitution by not issuing any warrants for

either the business or the personal examinations and not even being able to

show any probable cause whatsoever and not even conducting any examina-

tions over the entire five year period by supporting their searches with oath

or affirmation, and by conducting their search over a five year period for

both the business and personal without probable cause or any warrants; f.)

The IRS violates Article 7 - Amendment 5 of the U.S. Constitution when

the agent conducting the unreasonable search interrogates the Appellants by

attempting to compel the Appellants to admit to tax evasion even if its not

true, and when the agent(s) deprive the Appellants of liberty and property

without due process of law by violating Amendment 5 and all the other laws

mentioned and by not presenting an indictment of a Grand Jury, and because

the IRS separated the five years of 1979, 1980, 1981, 1982, and 1983 when

they issued their statutory notices of deficiencies instead of keeping them

all together as one entire audit as it is by the use of the Form 5213 (even

though that form was signed under duress from the IRS’s agent (s)) because

the year 1979 was left open for their determination until they had completed

the audits for 1980, 1981, 1982, and 1983 and then after they had postponed

‘See all original previous filings

the determination and completed the rest of the years, then they went back

and made their determination for all the years. g.) The IRS violates Article

7 - Amendment 6 of the U.S. Constitution when the IRS demanded to

inspect all the records and books of the Appellants-both personal and

business (the Appellants did not ask to be audited) and the entire audit is

prolonged over a five year period which was held in the appellees private

offices by bias agents who never informed the Appellants of the nature and

the cause of their accusation and who never provided the Appellants with

assistance of counsei for the Appellants defence. And if the The Civil Rights

Act of 1871 - Section 1983 does not protect the Appellants from all these

violations, are the Appellants protected anyway by the Laws themselves

under these mentioned circumstances.

2. In the Second Part of the Appellants Petition: If the Appellants are

protected by any and/or all laws mentioned in question | under the cir-

cumstances mentioned, does this also null and void the entire five year audit

(search and seizure) and/or in conjuction with the following additional vio-

lations of the Appellants Constitutional Rights by the IRS: a.) Article 7-

Amendment 7 - where the IRS never provided the Appellants with a jury;

b.) Article 7-Amendment 8-where the audit is prolonged over a five year

period of which the Appellees have to date taken up around seven years of

the Appellants time, and where the Appellees demanded the Appellants

produce records and books of which they did not have a right to inspect

demanding the Appellants do all that work and not compensating the Appel-

lants for the work and demanding that the Appellants come into their offices

- as to the ‘cruel and unusual punishment’ clause; c.) and Article 7 - Amend-

ment 13 - Section | - where the Appellees demand the Appellants to do all

the work involved in filling out all their forms for business and personal

which was not volunteered by the Appellants and where the Appellants

object to such involuntary servitude to the IRS of which their slavery has

no compensation from the IRS.

3. In the Third Part of the Appellants Petition - (the Counterclaim Petition):

Are the Appellants and on Behalf of the United States of America protected

from their enemy of the anti-Chirst/anti-Capitalistic/Socialistic-Type Prac-

tices of the Internal Revenue Service (such as the graduated Income Tax,

also, Social Security, pension type plans, and welfare programs funded by

taxation, also, taxation of services without being charged for what is actually

used-such as public schools and other practices of that nature all of which

extends from the Federal level to the State levels to the local levels) as

stated in the U. S. Constitution in Article 3 - Section 3, Article 4 - Section

4, Article 6 ‘Supremacy Clause’, and Article 7 - Amendments 1, 4, 5, 13

- Section 1; and also, the Declaration of Independence, The Federalist, The

Civil Rights Act of 1871! - Section 1983 and The Holy Bible. If the Appellants

and on Behalf of the United States are protected against this enemy by any

and/or all these Laws, are they then entitled to a repeal of Article 7-Amend-

ment 16 of the U. S. Constitution and to have the Governmental System

restructured to comply with the U. S. Constitution as resembling that « ‘hich

the Appellants have shown in their Proposal of a Christian/Capitalistic-Type

Practices and Proclaim this Enemy Null! and Void.

4. Does the ‘Due Process’ Clause in Article 7, Amendment 5 and the

‘Petition’ Clause in Article 7, Amendment | in the U. S. Constitution provide

for the Appellants the right to receive a decision based upon the merits of

the Appellants Brief of the Merits from the U. S. Court of Appeals.

5. If these Clauses mentioned in question 4 do entitle the Appellants to a

decision based upon the Merits of the Appellants Brief on the Merits by the

U. S. Court of Appeals and the Court refuses to render a decision based

upon the Merits of the Brief, does that entitle the Appellants to have their

Petition for Writ of Certiorari/Petition for Writ of Certiorari before Judgment

Granted by the U. S. Supreme Court enabling the Appellants to receive a

decision from the U. S. Supreme Court based upon the Merits of the Appel-

lants Brief on the Merits in its entirety as a matter of judicial discretion and

judicial review.

6. If the U. S. Appeals Court did violate the Petitioners Rights as stated in

questions 4 and 5 as to the ‘Due Process’ Clause in Article 7-Amendment

5 and the ‘Petition’ clause in Article 7-Amendment | of the U. S. Constitu-

tion, did they then-at that time-also violate Article 6 in the U. S. Constitution

as to the ‘Supreme Law of the Land’ Clause.

7. Do Questions 1, 2, and 3 of the Questions Presented Merit and Justify

the U. S. Supreme Court to Grant the Appellants Petition for Writ of Cer-

tiorari/Petition for Writ of Certiorari before Judgment as a matter of Judicial

Discretion and Judicial Review in its entirety.

3

TABLE OF CONTENTS

Pages

Sa aS ae OE ROL er ae eRe R aE ee

sh a Bak Gog oe ole hw kp el ¥ON ae ke Oe ies 4

ae ee es eee ee ee er ae ar 5

Petition for a Writ of Certiorari/

Petition for a Writ of Certiorari

Before Judgement

i i aoe tk sg sk kK wie RO 8

Entry of Judgement and Notice of Appeal ................ 9

Statutory Provision to Confer

AE On ae eee ae ae 9

Sk bk 6 hone a ee 8 be eS oe ws 9

Constitutional Provisions, Acts and Reguiations ............ 10

ala ge Sw a BAK Bike ee aw oe oes Be 14

Argument Amplifying Reasons for the Allowance

NE a aa sgt aa a a op era dk Neate, bee a a eee 16

dn aes) CF hag cha brg ata woes ol eM hee ee 19

oh gh eg Hoge. Wa ene Bie BOTA eR Ae on a 20

Appendix A - Statement of Review of Appellants Brief ....... 21

Appendix B - Order Appealed From ................... 22

Appendix C - Opinion of Commissioner ................. 23

Appendix D - Order from the U. S. Court of Appeals ........ 24

Appendix E - Order From the U.S. Tax Court ............ 25

pepemees © - MOGCR OT ADDON 2 we eee 27

Appendix G - Miscellaneous Statement ................. 28

TABLE OF AUTHORITIES.

Cases: a Pages

1. Ashbaugh v. Sims - 483 SW2d 80 (Mo. App. 1972) .. 1-28

2. Ashwander v. Tennessee Valley Authority - 297 U.S. 288 -1935 1-28

3. Be @. Ge = Fae We Oe OE OOS ee ee 1-28

4. Beightol v. Kunowski - (1973, CA3 Pa) 486 F2d 293, on

Remand (MD Pa) 382 F Supp 985 ............. 1-28

5. Byran v. Jones - (1976, CAS Tex) 530 F2d 1210, cert den 429

Uo Gea, Sau, ea 28 345, 97 SO TM. 8 ese 1-28

6. Carter v. Carter Coal Co. - 298 U.S. 238 (1936) ooo Bean

7. Christ v. anti-Christ

ah.

. Duncan v. Nelson - (1972, CA7 Ill) 466 F2d 939, 945, cert den 409

U.S. 894, 34 L Ed 2d 152, 93 Ct 116,93 SCt 175. .. 1-28

. Escobedo v. Illinois - 378 U.S. 473 (1964) ........ 1-28

. Ex parte Quirin - 317 U.S. 1(1942) .. 2.2.0.0... 1-28

. Ford v. Wells - (1972, Ed Tenn) 347 F Supp 1026 ... 1-28

[ . . »8§ 2 | PTT Lea CLE re Ce ee 1-28

. Honeyfield v. Lambeth - 519 SW2d 342 (Mo. App. 1975) . 1-28

. Jenkins v. Averett - (1970, CA4 NC) 424 F2d 1288, 1232 . 1-28

. Katz v. United States - 389 U.S. 347 (1967) ....... 1-28

. Kucinich v. Forbes - (1977, ND Ohio) 432 F Supp 1101 . 1-28

. Leeson v. Etchinson - 650 SW2d 681 (Mo. App. 1983) . 1-28

. Mansell v. Saunders - (1967, CAS Fla) 372 F2d 573... =1-28

. Maney v. Ratcliff - (1975, Ed Wis) 399 F Supp 760 .. 1-28

. Marbury v. Madison - U.S. (1 Craunch) 137 (1803) ... 1-28

Miranda v. State of Arizona - 86 S. Ct. 1602 (1966) .. 1-28

‘See all previous original filings

dee U.S. Supreme Court Rules - Rule 18.

See U.S. Supreme Court Rules - Rule 18.

22. Monroe v. Pape - (1961) 365 U.S. 167, 5 L Ed 2d 492, 81

ces a aa acre, Weare oot, Aan ela 1-28

23. Railroad Retirement Board v. Alton R.. Co. - 295 U.S. 330

NE te hea iin ee gh 1-28

24. Rickert Rice Mills v. Fontenot - 297 110 (1936). ...... 1-28

25. United States v. Banker Trust Co. - 294 U.S. 240 (1935). 1-28

26. United States v. Mine Workers - 330 U.S. 258 (1947).” .. . 1-28

27. United States v. Nixon - 94 S. Ct. 3090 (1974) ........ 1-28

28. Wilson v. Girard - 354 U.S. 524 (1957)... 2... 1-28

29. Youngstown Sheet & Tube Co. ¥. Sawyer - 343 U.S. 579

NE 40. fk ee a ee 1-28

Constitutional Provisions:

i Ms 6. 5 ka 4m oe 8 ee aw eR 1-28

GN 5 Eee eee eee Tere eee 1-28

ee ere 1-28

Ne act gS Sw 4G te, nak Sublet ee 1-28

>. Meco 7-Amendmem 1 ..... 1... . cece 1-28

Oy Ee ee 1-28

a SS 1-28

eee ¢ ~ POE kk i ce cee ee ewe 1-28

ey ee eee 1-28

Oe ee er ee 1-28

11. Article 7 - Amentment 13 - Section! .............. 1-28

12. A Repeal of Article 7- Amendment 16 ............. 1-28

Acts:

1. Civil Rights Act of 1871 - Section 1983 ............. 1-28

‘See U.S. Supreme Court Rules - Rule 18.

See U.S. Supreme Court Rules - Rule 18.

ee U.S. Supreme Court Rules - Rule 18.

soce U.S. Supreme Court Rules - Rule 18.

nee U.S. Supreme Court Rules - Rule 18.

See U.S. Supreme Court Rules - Rule 18.

Statutes/Regulations: r

1. Federal Civil Rights Statute (42 USCS § 1983) ........ 1-28

2. Section 7482 (a) (1) of the Internal Revenue Code of 1986

| EPEC 6 RL ee aS 1-28

3. Code Sec. 446 § 4060 - “Adequacy of Records’ ........ 1-28

4. Code Sec. 274 § 3592 - ‘Oral Evidence’ ............ 1-28

5. Code Sec. 6001 § 6561 - ‘Records, Statements, & Special Returns’

6. ‘Field Examinations of Returns’ - § 15,019 ........... 1-28

7. Section 7459(c) of the Internal Revenue Code aS ans 1-28

Miscellaneous:

1. The People’s Power - by Charles P. Sohner-E] Camino College

Se ee ee ee ee ee ee eg ee eee 1-28

2. The Legal Environment of Business - by Robert N. Corley

- University of Georgia, Robert Black - University of Illinois,

O. Lee Reed - University of Georgia, - 1977......... 1-28

3. Fundamentals of the Legal Environment of Business - By Robert

N. Corley - University of Georgia, O. Lee Reed - University

ee ee et a ees ke hee 88 1-28

4. College Law for Business - by John D. Ashcroft - Attorney General

- State of Missouri, Janet E. Ashcroft - General Counsel-

Missouri Department of Revenue - 1981 ............ 1-28

5. Federal Civil Rights Acts - Civil Practice - by Chester J.

Antieau - 2nd Edition- 1980 .................. 1-28

6. The Declaration of Independence ....................

7. The Federalist - by Alexander Hamilton, James Madison, and

I te ee tie ey a pA A Akh So hh OS Ce 1-28

8. The Holy Bible.

ae aks sk ye oe oe ee Oe a 1-28

9. FR Fe A POG gw in eee ee ees 1-28

10. The St. Lows Giobe-Democtat 2. ww ees 1-28

"See Federal Tax Guide Reports - Code Sec. 446 § 4060, Code Sec. 274 § 3592, Code

Sec. 6001 § 6561, & ‘Field Examinations of Return’ - § 15,019.

“See filing of Commissioner’s Response dated 4/6/87.

"See filing of Commissioner’s Response dated 4/6/87.

7

In She

Supreme Court Of The United States

October Term, 1986

No. 86-

Carlyn M. and Carol J. Johnson

C-Me-J Enterprises

Appellants,

v.

Commissioner of Internal Revenue

Internal Revenue Service

Appellees.

PETITION FOR A WRIT OF CERTIORARI/

PETITION FOR A WRIT OF CERTIORARI

BEFORE JUDGEMENT

OPINIONS BELOW

It is the Opinion of the U.S. Court of Appeals for the Eighth Circuit

that the Appellants case be dismissed without prejudice by rendering a

decision that they did not base their decision upon the Merits of the Appellants

Brief (Proof). It is the Opinion of the U. S. Tax Court’ that the taxable

years of 1979, 1980, 1981, & 1983 be dismissed for lack of jurisdiction -

accepting only 1982."

14 & 16 . . :

These captions contains the names of all the parties.

"See all original previous filings. The Commissioner disagreed with the U.S. Court of

Appeals.

See all original previous filings.

ENTRY OF JUDGMENT AND NOTICE OF APPEAL:

The Order from the U. S. Tax Court was entered on November 24, 1986.

The Order from the U. S. Court of Appeals was entered on April 10, 1987.

The Appellants filed a Notice of Appeal from the U. S. Tax Court to the

U. S. Court of Appeals for the Eighth Circuit two times, one on September

26, 1986 (which the U. S. Tax Court misconstrued as a ‘Motion to Vacate’)

and then again on December 7, 1986.

STATUTORY PROVISION TO CONFER JURISDICTION:

Article 3 of the U.S. Constitution confers original jurisdiction; also Article

1-Section 8, Article 3-Section-3, Article 4 - Section 4, Article 6, Articie

7-Amendments 1, 4, 5, 6, 7, 8, 13-Section 1, and a Repeal of Article

7-Amendment 16 of the United States Constitution confers jurisdiction to

this court. The Appellants provided proof (their brief) that the U. S. Tax

Court lacked jurisdiction in the United States to the U. S. Appeals Court,

the U. S. Appeals Court refused to base their decision to dismiss on the

Appellants Brief (Proof). As stated in Article 6 of the Constitution in the

‘Supremacy Clause’ is that, therefore, the U. S. Tax Court is Notwithstanding

because its to the Contrary of the U. S. Constitution. Also, Section 7482(a)(1)

of the Internal Revenue Code of 1986 (26 U.S.C.) and Section 7459 (c) of

the Internal Revenue Code provide for Jurisdiction in this U.S. Supreme

Court. Also, the original previous filings as shown in the Appellants original

Brief provide for Jurisdiction in this U.S. Supreme Court. Also, Federal

Civil Rights Statute (42 USCS § 1983) provides jurisdiction. It would be

best to review the entire case to receive a full understanding of the case (as

much as possible anyway) especially since the decision of the U.S. Court

of Appeals was not to make a decision based upon the proof.

CASES SUSTAINING JURISDICTION: »

Christ v. anti-Christ, Marbury v. Madison - U. S. (1 Craunch) 137 (1803),

United States v. Nixon - 94 S.Ct. 3090 (1974), Escobedo v. Illinois - 378

U.S. 473 (1964), Miranda v. State of Arizona - 86 S.Ct. 1602 (1966), Katz

v. United States - 389 U.S. 347 (1967), Baker v. Carr - 369 U.S. at 211,

Ashwander v. Tennessee Valley Authority - 297 U.S. 288 - 1935, Ashbaugh

“See previous original filings & Table of Authorities.

9

v. Sims - 483 SW2d 80 (Mo. App. 1972), Leeson v. Etchinson - 650 SW2d

681 (Mo. App. 1983), Honeyfield v. Lambeth - 519 SW2d 342 (Mo. App.

1975), Honeyfield at 521, United States v. Banker Trust Co. - 294 U.S.

240 (1935), Railroad Retirement Board v. Alton R. Co. - 295 U.S. 330

(1935), Rickert Rice Mills v. Fontenot - 297 U.S. 110 (1936), Carter v.

Carter Coal Co. - 298 U.S. 238 (1936), Ex parte Quirin - 317 U.S. 1 (1942),

United States v. Mine Workers - 330 U.S. 258 (1947), Youngstown Sheet

& Tube Co. v. Sawyer - 343 U.S. 579 (1952), Wilson v. Girard - 354 U.S.

524 (1957), Beightol v. Kunowski - (1973, CA3 Pa) 486 F2d 293, on

Remand (MD Pa) 382 F Supp 985, Bryan v. Jones - (1976, CAS Tex) 530

F2d 1210, cert den 429 US 865, 5OL Ed 2d 145, 97 S Ct. 174, Duncan v.

Nelson - (1972, CA7 I11) 466 F2d 939, 945, cert den 409 US 894, 34 L

Ed 2d 152, 93 S Ct 116, 93 S Cf 175, Ford v. Wells - (1972, Ed Tenn)

347 F Supp 1026, Jenkins v Averett - (1970, CA4 NC) 424 F2d 1288,

1232. Kucinich v. Forbes - (1977, ND Ohio) 432 F Supp 1101, Mansell v.

Saunders - (1967, CAS Fla) 372 F2d 573, Maney v. Ratcliff - (1975, ED

Wis) 399 F Supp 760, Monroe v. Pape - (1961) 365 US 167, 5 L Ed 2d

492, 81 S Ct 473.

CONSTITUTIONAL PROVISIONS, ACTS & REGULATIONS

U. S. Constitution:

Article 7 - Amendment | (Petition) Clause; ‘Congress shall make no

law...abridging the...right of the people...to petition the Government for a

redress of grievances.’, Article 7-Amendment 5 (Due Process) Clause; ‘nor

be deprived of life, liberty, or property, without due process of law;’,

Article 1 - Section 8, in pertinent part-‘To raise and support Armies, but

no Appropriation of Money to that Use shall be for a longer Term than two

Years;’, Article 3 - Section 3, ‘Treason against the United States, shall

consist only in levying War against them, or in adhering to their Enemies,

giving them Aid and Comfort. No person shall be convicted of Treason

unless on the Testimony of two Witnesses to the same overt Act, or on

Confession in open Court. The Congress shall have Power to declare the

Punishment of Treason, but no Attainder of Treason shall work Corruption

of Blood, or Forfeiture except during the Life of the Person attainted.’,

Article 4 - Section 4, ‘The United States shall guarantee to every State in

See original filings

this Union a Republican Form of Government, and shall protect each of

them against Invasion; and on Application of the Legislature, or of the

Executive (when the Legislature cannot be convened) against domestic

Violence.’, Article 6, in pertinent part-‘This Constitution, and the Laws of

the United States which shall be made in Pursuance thereof; and all Treaties

made, or which shall be made, under the Authority of the United States,

shall be the Supreme Law of the Land; and the Judges in every State shall

be bound thereby, any Thing in the Constitution or Laws of any State to

the Contrary notwithstanding.’, Article 7 - Amendment | - ‘Congress shall

make no law respecting an establishment of religion, or prohibiting the free

exercise thereof; or abridging the freedom of speech, or of the press; or the

right of the people to assemble, and to petition the Government for a redress

of grievance.’, Article 7 - Amendment 4 - ‘The right of the people to be

secure in their persons, houses, paper, and effects against unreasonable

searches and seizures, shall not be violated, and no Warrants shall issue,

but upon probable cause, supported by Oath or affirmation, and particularly

describing the place to be searched, and persons or things to be seized.’,

Article 7 - Amendment 5, in: pertinent part-‘nor shall be compelled in any

criminal case to be a witness against himself, nor shall be deprived of life,

liberty, or property, without due process of law.’ and again in Amendment

5-‘No person shall be held to answer for a capital, or otherwise infamous

crime, unless on a presentment or indictment of a Grand Jury, except in

cases arising in the land or navel forces, or in the Militia, when in actual

service in time of War or public danger; nor shall any person be subject for

the same offense to be twice put in jeopardy of life or limb; nor shall be

compelled in any criminal case to be a witness against himself, nor be

deprived of life, liberty, or property, without due process of law;-nor shall

private property be taken for public use, without just compensation.’, Article

7 - Amendment 6-‘In all criminal prosecutions, the accused shall enjoy the

right to a speedy and public trial, by an impartial jury of the State and

district wherein the crime shall have been committed, which district shall

have been previously ascertained by law, and to be informed of the nature

and cause of the accusation; to be confronted with the Witnesses against

him; to have compulsory process for obtaining witnesses in his favor, and

to have the Assistance of Counsel for his defence.’, Article 7 - Amendment

7-‘In Suits at common law, where the value in controversy shall exceed

twenty dollars, the right of the trial by jury shall be preserved, and no fact

tried by a jury, shall be otherwise re-examined in any Court of the United

States, than according to the rules of common law.’, Article 7 - Amendment

8-‘Excessive bail shall not be required, nor excessive fines imposed, nor

cruel and unusual punishments inflicted.’, and Amendment 13-Section 1-

‘Neither slavery nor involuntary servitude, except as a punishment for crime

whereof the party shall have been duly convicted, shall exist within the

United States, or any place subject to their jurisdiction’. The Appellants

seek a repeal to Amendment 16 of the Constitution which states: ‘The

Congress shall have power to lay and collect taxes on incomes, from whatever

source derived, without apportionment among the several States, and without

regard to any census or enumeration.” as unconstitutional.

Acts: :

Civil Rights Act of 1871-Section 1983-[This creates tort liability for any

public official or employee who injures a person by depriving him or her

of constitutionally guaranteed rights. Through interpretation, the Supreme

Court has extended this liability to municipal governments that support such

behavior by “custom, practice, or policy”. An example of constitutionally

guaranteed rights - called “civil rights” - is the Fourteenth Amendment

right not to be deprived of life, liberty, or property without due process;

other examples are the first, fourth, and fifth amendments. Areas of Potential

Liability are 1.) Use of zoning for political or discriminatory purposes. 2.)

Failure to train and supervise public employees. 3.) Use of permit, inspection,

or licensing procedures for political, harassing, or discriminatory purposes. ¢

(In pertinent part-paraphrased and summarized)

Regulations:

Federal Civil Rights Statute (42 USCS § 1983). Section 7482(a)(1) of the

Internal Revenue Code of 1986 (26 U.S.C.) - [In General - The United

States Court of Appeals (other than the United States Court of Appeals for

the Federal Circuit) shall have exclusive jurisdiction to review the decisions

of the Tax Court, except as provided in section 1254 of Title 28 of the

United States Code, in the same manner and to the same extent as decisions

of the district courts in civil actions tried without a jury; and the judgment

of any such court shall be final, except that it shall be subject to review by

the Supreme Court of the United States upon certiorari, in the manner

See original previous filings (*Appellants Brief).

12

provided in section 1254 of Title 28 of the United States Code.]

Federal Tax Guide Reports: Code Sec. 446 § 4060 - ‘Adequacy of Records.

Any original record, such as a cancelled check or a receipt is an adequate

record of a particular expenditure. Similarly, other single transactions are

normally supported adequately if related original records or documents are

retained, whether in a formal or informal matter. With regard to the records

that are specifically required to be kept, see § 6561. The nature of records

to be kept will, of course, vary with the needs of the particular taxpaper.’

(As stated in pertinent part). Code Sec. 274 § 3592 - ‘Oral Evidence - A

taxpayer's statement as to the amount, time and place, business purpose,

and busines relationship can be substantiated by oral evidence as well as by

written evidence. The IRS has issued instructions to its examiners that they

can accept oral evidence, so long as the evidence is not improbable or

unreasonable, self-contradictory } or inconsistent with surrounding facts and

circumstances(.10).’(As stated in pertinent part). Code Sec. 6001 § 6561

-[‘Records, Statements, and Special Returns - However, the law that compels

taxpapers to maintain records and file returns does not entitle the IRS to

inspect them without an Administrative Summons(.035).’ and ‘The govern-

maent may only require production of records relating to the liability of the

person to whom the notice to produce is directed and not production of all

books, papers, records, or other data that may be relevant to an investigation

(.10). Production of these materials may be ordered under the. Summons

provision discussed at § 6969.’] (As stated in pertinent part. o § 15,019

-‘Field Examinations of returns - Therefore, if the taxpayer is engaged in a

trade or business and has an established place of business, the revenue agent

will conduct the examination at the taxpayer's place of business.’ (As. stated

in pertinent part. y Section 7459(c) of the Internal Revenue Code” - in

pertinent part - ‘if the Tax Court dismisses a proceeding for lack of jurisdic-

tion, an order to that effect shall be entered in the records of the Tax Court,

and the decision of the Tax Court shall be held to be rendered upon the date

of such entry.’

“See filing - Commissioners Response to taxpayers - 4/6/87

‘8 "See original filing of Appellants Brief.

“See original filing of Appellants Brief.

“See original filing of Commissioners Response - 4/6/87.

STATEMENT OF THE CASE:

This is an action by P**tioners Carlyn M. And Carol J. Johnson (C-Me-J

Exterprises), who seeks Yen Million Dollars in Actual & Punitive Damages

& an acceptance of the Petitioners Tax returns as originally filed (including

the amended returns) that had been submitted within the tax laws and who

also seek to have the entire five year audit nullified and voided. The Appel-

lants further seek to have the Internal Revenue Service Agency declared

unconstitutional including the U.S. Tax Court as they are engaged in the

same socialistic-type of activities as the Internal Revenue Service. After

declaring the Internal Revenue Service and the U. S. Tax Court null and

void, we want the Governmental System restructured in compliance with

the United States Constitution of America and the Declaration of Indepen-

dance in such a manner as to resemble the proposal submitted by the Petitioner

in a reasonable fashion and an enforcement of a Phase-Out Plan for the

Social Security Settlement. The Petitioners Petition is composed of Three

Parts as stated above - 1.) Accepting the Petitioners tax returns (including

the amended returns) as originally submitted; 2.) Declaring the entire audit

null and void; 3.) Declaring the Internal Revenue Service and the U. S. Tax

Court null and void. :

The First Part of the Petitioners Petition. alleges that the IRS agents

violated the Petitioners Rights pursuant the Civil Rights Act of 1871-Section

1983 by violating the following Laws: a.) Code 446 § 4060, Code 274

§3592, Code 6001 § 6561, and ‘Field Examinations of Returns’-§ 15,019

of the IRS Rules & Regulations in the Federal Tax Guide Reports; b.) Article

7-Amendment 4 of the U.S. Constitution; c.) Article 7-Amendment 5 of

the U.S. Constitution; and d.) Article 7-Amendment 6 of the U.S. Constitu-

tion. Also, regardless of the Civil Rights Act of 1871-Section 1983, the

Petitioners allege that the IRS (agents) violated these mentioned Laws within

the Laws themselves.

The Second Part of the Petitioners Petition alleges that since the IRS

(agents) violated all the Laws mentioned in Part One of the Petition, then

the entire five year audit is null and void and/or in conjunction with the

following Laws violated, the entire five year audit is null and void: a.)

“See all original filings

«See original filing of Appeilants Brief.

See Constitutional Provisions, Acts & Regulations.

see Constitutional Provisions, Acts & Regulations.

14

Article 7-Amendmeat 7 of the U.S. Constitution; b.) Article 7-Amendment

8 of the U.S. Constitution; and c.) Article 7-Amendment 13-Section | of

the U.S. Constitution.

The Third Part of the Petitioners Petition consists of a Counterclaim

Petition that was filed on behalf of the United States of America which

alleges that the Internal Revenue Service is engaged in socialistic-t pe ac-

tivities thereby resulting in violations of the U.S. Constitution of - 1.)

Article 3 - Section 3; 2.) Article 4 - Section 4; 3.) Article 6 - ‘Supremacy

Clause’; 4.) Article 7 - Amendment 1, 4, 5, 13 - Section 1; 5.) It declares

Article 7-Amendment 16 null and void; and 6.) violations of the U.S.

Constitution Biblical of a) Matthew, Chapter 22-versus 17-22; b) Matthew,

Chapter 17-versus 24-27; c) Matthew, Chapter 15-versus 32-39; d) Mark,

Chapter 12-versus 41-44; e) Luke, Chapter 23-versus 1-3; and f) Matthew,

Chapter 9-versus 9-13; and violations of 7.) The Declaration of Indepen-

dence. The Counterclaim then offers a proposal as an alternative to the

socialistic-type practices that complies with the U. S. Constitution that

consists of capitalistic-type and donations (capitalistic)-type practices for

the U. S. Treasurer.

The U. S. Tax Court then issued an order dated November 24, 1986 that

stated the court dismissed for lack of jurisdiction taxable years of 1979,

1980, 1981, and 1983 stating no statutory notice of deficiency was issued

for those years and they would only accept 1982. The Appellants disagreed

stating that Form 5213 tied all five years together thereby constituting one

entire audit and that the Petitioners did receive a notice of deficiency for

1979, 1980, and 1983 and appealed the case to the U. S. Appeals Court

for Eighth Circuit. After the U. S. Appeals Court accepted the Appeal, they

issued an order stating that the due date for the Appellants Brief was due

March 9, 1987. On Janurary 30, 1987, the Appellants filed for an extension

for the due date of the Brief which was granted until April 9, 1987. After

the Appellants prepared the Brief and were ready to send it in to the U. S.

Appeals Court, the Appellants received a court order dated March 23, 1987

stating that the case was dismissed without prejudice for lack of jurisdiction

which was a contradiction of the previous order accepting our appeal. On

March 25, 1987, the Appellants filed a ‘Motion for Reconsideration to be

based upon the contents of the Brief’ in response to the order dated March

23, 1987. In the meantime, the Appellee filed a response to the taxpayers’

"See Constitutional Provisions, Acts & Regulations.

ee original filing of Appellants Brief.

- See original previous filings - Appellants Brief.

15

motion for reconsideration dated April 6, 1987 agreeing with the taxpayers

motion for reconsideration of Jurisdiction. Then, the Appellants received a

court order dated April 10, 1987 dismissing the Appellants motion for

reconsideration stating their decision was not based upon the merits of the

brief but merely recognized requirements had not been met and that dismissal

was without prejudice. The basis for federal jurisdiction in the court of the

first instance was that the Appellants received a statutory notice of deficiency

from the Internal Revenue Service of which the Appellants have since aban-

doned to the U. S. Appeals Court as the U. S. Tax Court does not have

any jurisdiction in the United States which left the U. S. Appeals Court

with jurisdiction pursuant the U. S. Constitution and other Laws which the

Appellants Brief provides proof of,

ARGUMENT AMPLIFYING REASONS FOR THE ALLOWANCE

OF THE WRIT’S ~

The Petition for Writ of Certiorari/Petition for Writ of Certiorari before

Judgment should be granted for the following reasons: In some respects the

Appellants have received final decisions and in other respects the Appellants

have not received final decisions. In the first part of the Appellants Petition,

Pursuant to Section 7459(c) of the Internal Revenue Code, the U. S. Tax

Court gave its final decision regarding the First Part of the Appellants Petition

that was to Dismiss taxable years 1979, 1980, 1981, and 1983 for lack of

jurisdiction, which pursuant to Section 7482(a)(1) of the Internal Revenue

Code of 1986 (26 U.S.C.) gave the U. S. Appeals Court for the Eighth

Circuit jurisdiction as the Appellants appealed their case from the U. S. Tax

Court. Also, at that time, the Appellants, due to the decision of the U.S.

Tax Court, then filed the same case as ‘Double Jeopardy’ in the U.S. Tax

Court-currently docket No. 45188-86 and then again as ‘Triple Jeopardy’

in the U.S. District Court-Eastern District of Missouri-Eastern Division-cur-

rently as case No. 86-2541-C-3. Then the U. S. Appeals Court dismissed

the case and refused to base their decision which was not to make a decision

based upon the Merits of the Appellants Brief that was submitted to them.

The Appellants, therefore, have no other Court to turn to for a decision on

the First Part of the Appellants Petition which encompasses the Second and

Third Part of the Petition because the U. S. Appeals Court has denied us

“See all original filings

our right to the ‘Due Process’ Clause in Article 7-Amendment 5 and the

‘Petition’ Clause in Article 7-Amendment }.

The Petition for Writ of Certiorari/Petition for Writ of Certiorari before

Judgment should be granted for the following reasons: The Second Part of

the Appellants Petition consists of voiding the entire audit due to all the

constitutional rights of Appellants that were violated by the Appellees and

ail other laws involved (Please see the Questions Presented in the first part

of this Certiorari; the Constitutional Provisions, Acts, and Regulations; and

all previous original filings). As the U. S. Constitution is the Supreme Law

of the land, the Appellants Constitutional Rights are important. As the

Appellants appealed their case to the U. S. Court of Appeals - the other

two parts (Part 2 and 3) of the Appellants Petition went right along with

the first Part of the Petition as all three parts are one - which the U. S.

Appeals Court made the decision of not to base their decision upon the

merits of the Appellants Brief. As shown in Marbury v. Madison- U. S. (1

Craunch) 137 (1803) and United States v. Nixon - 94 S.Ct. 3090 (1974),

the U. S. Constitution is the Supreme Law of the Land of which the U. S.

Supreme Court may void the rule the U. S. Appeals Court stated as basing

their decision to dismiss of which they refused to base their decision upon

the Merits of the Appellents Brief.

The Third Part of the Appellants Petition which consists of the Coun-

terclaim Petition is also part of the first and second part of the petition. This

Counterclaim Petition (as shown in the Appellants Brief) consists of declaring

the IRS and the U. S. Tax Court null and void. The Nationai Security is at

stake as indicated in the Counterclaim Petition and the Appellants Brief.

Since the Internal Revenue Service is engaged in anti-Christian/anti-capitalis-

tic/socialistic-type practices which is forbidden by the U. S. Constitution

and Declaration of Independence and the other Laws stated, the importance

of this matter concerns the Public as imperative to have the Writs Granted.

The Appellants have offered a Proposal that represents the Majority of the

Nation that is based upon Christian/Capitalistic-type practices in which the

U. S. Treasurer may conduct its finances which complies with the U. S.

Constitution. As stated in the Appellants Brief in Article 4 - Section 4 of

the U. S. Constitution in pertinent part, ‘The United States shall guarantee

to every State in this Union a Republican Form of Government’ which not

only means a Democracy (of which the Internal Revenue Service is depriving

the Judeo-Christian Faith of as the majority of the Nation are of Judeo-Chris-

tian Faith) but it also refers to the Republican Party-(meaning Capitalism

as well) which years ago was one party ticket called the ‘Democratic-Repub-

lican’ Party ticket that was led by Thomas Jefferson and James Madison.

But through the years, the Internal Revenue Service has turned this one

party ticket into a two party ticket that is communistic/socialistic in nature.

The Internal Revenue Services does not offer the Majorities Ticket. The

Internal Revenue Service are Professional Terrorists. They make a mockery

of the U. S. Constitution, Christianity, The Declaration of Independance,

and other Laws that are deeply imbedded in our society. The Internal Revenue

are Anti-Capitalists of which their socialistic-type practices not only stem

from Socialism but Communism as well (As shown in the Exhibits of the

Appellants Brief). One only needs to read the Newspaper to get an idea of

how violent these terrorists can really become as in other countries around

the world. As shown in the Appellants Exhibits in their Brief, these Anti-

Capitalists have as part of their doctrine - violent terrorist attacks as their

plans. They do not recognize individual rights as in the U. S. Constitution.

Every second that goes by, people all over the country are subjected to their

violence - some are subjected to a greater degree of their violence than

others. If the Appellants Writs are not Granted - this may only prolong and

increase their terrorism reign. If these Anti-Capitalist Terrorists are not

stopped now, it will, more than likely, get much worse as the Communists/

Socialists become stronger. As indicated in such cases as United States v.

Banker Trust Co. - 294 U.S. 240. (1935), Railroad Retirement Board v.

Alton R. Co., -295 U.S. 330 (1935), Rickert Rice Mills v. Fontenot - 297

U.S. 110 (1936), Carter v. Carter Coal Co. - 298 U.S. 238 (1936), Ex parte

Quirin - 317 U.S. 1 (1942), United States v. Mine Workers - 330 U.S. 258

(1947), Youngstown Sheet & Tube Co. v. Sawyer - 343 U.S. 579 (1952),

Wilson v. Girard - 354 U.S. 524 (1957) and United States v. Nixon - 94

S.Ct. 3090 (1974), the Appellants (and on behalf of the United States of

America) Counterclaim Petition and the Appellants Petition in its entirety

of which these Writ’s of Certiorari’s are written are definately of the Public

Importance as to Justify having the U. S. Supreme Court Grant the Appellants

Petition for Writ of Certiorari/Petition for Writ of Certiorari before Judgment.

Furthermore, the Appellants are entitled to a speedy and public trial as

stated in pertinent part in Article 7-Amendment 6 in the U. S. Constitution

- ‘the accused shall enjoy the right to a speedy and public trial’ of which

the Internal Revenue Service has already dragged this whole ordeal out for

about seven (7) years.

CONCLUSION

The Appellants Petition for Writ of Certiorari/Petition for Writ of Certiorari

before Judgment should be Granted by the United States Supreme Court.

Respectfully Submitted,

Carlyn M. & Carol J. Johnson

11987 Brookmont Drive

Maryland Heights

Missouri, 63043

(314) 739-8326

Pro-Se

APPENDICES

20

STATEMENT OF REVIEW OF APPELLANTS BRIEF

This statement signifies that it is imperative that the Appellants Brief

(Brief on the Merits) filed in the U.S. Court of Appeals for the Eighth

Circuit is reviewed along with these Writs - the Petition for Writ of Certiorari/

Petition for Writ of Certiorari before Judgment.

It is also imperative that the Review is from the Original Brief filed in

the U. S. Court of Appeals as the Appellants have highlighted the material

to be read in Yellow on some of the Exhibits.

Appendix A

21

UNITED STATES COURT OF APPEALS

For the Eighth Circuit

No. 87-1131

Carlyn M. and Carol J. Johnson

(C-Me-J Enterprises)

Appellants,

v.

Commissioner of Internal Revenue

(Internal Revenue Service)

Appellees.

Date Filed + April 10, 1987

ORDER

On March 23, 1987 we dismissed petitioners’ appeal for lack of jurisdic-

tion. Before us now is petitioners’ request that we reconsider that decision.

The facts leading to this appeal were given in our March 23 order and

do not merit repeating. Petitioners argue that our decision was premature

because it preceded the filing of briefs. We should reconsider our decision,

they argue, in light of their recently filed brief. Upon reconsideration we

affirm our earlier dismissal for the same reasons as given in the March 23

order.

We neither agree nor disagree with the arguments on the merits made by

petitioners. We merely hold that this is not the time to decide them. Once

the Tax Court reaches a final decision on petitioners’ 1982 tax liability,

petitioners may then appeal that decision, if necessary, as well as the order

pertaining to the years 1979, 1980, 1981, and 1983. Until such time, how-

ever, the order pertaining to these four years is not final and consequently

not_appealable. This decision does not go to the merits of petitioners’ argu-

ments -- it merely recognizes that threshold jurisdictional requirements have

not been met. Further Petitioners’ argument and Contention that these re-

quirements are inapplicable because the Tax Court lacked jurisdiction are

frivolous and specious and requires no further comment.

The appeal is therefore dismissed without prejudice.

Appendix B

9

ne

UNITED STATES COURT OF APPEALS

For the Eighth Circuit

No. 87-1131

Carlyn M. and Carol J. Johnson

(C-Me-J Enterprises)

Appellants,

Vv.

ne Commissioner of Internal Revenue

(Internal Revenue Service)

Appellees.

Date Filed: April 6, 1987

OPINION IN PERTINENT PART

COMMISSIONER’S RESPONSE TO

TAXPAYERS’ MOTION FOR RECONSIDERATION

By order dated March 23, 1987, this Court dismissed the Taxpayers’

appeal in the above-entitled case for lack of jurisdiction, reasoning that the

decision appealed from was not appealable since it did not dispose of all

tax years involved in the suit. Taxpayers have moved the Court to reconsider

its dismissal. Because the order of the Tax Court dismissing taxpayers’

petition for their 1979, 1980, 1981, & 1983 tax years constitutes the final

decision of the court with respect to proceedings for those years, we believe

this Court has jurisdiction to review that decision under Section 7482(a)(1)

of the Internal Revenue Code of 1986 (26 U.S.C.).

Stamped /s/

Michael L. Paup

Appendix C

23

UNITED STATES COURT OF APPEALS

For the Eighth Circuit

No. 87-1131

Carlyn M. and Carol J. Johnson

(C-Me-J Enterprises)

Appellants,

aa!

Commissioner of Internal Revenue

(Internal Revenue Service)

Appellees.

ORDER

The Court will consider this appeal on the original file of the United

States Tax Court. The Clerk of the Tax Court is requested to forward the

original file in case no. 14576-86 to this Court forthwith.

Appellants Brief - due March 9, 1987

Appellee Brief - due April 8, 1987

Order entered under Rule 5(a): :

[Date Filed - January 27, 1987]

Appendix D

24

UNITED STATES TAX COURT

No. 14576-86

Carlyn M. and Carol J. Johnson

(C-Me-J Enterprises)

Petitioners,

Vv.

Commissioner of Internal Revenue

(Internal Revenue Service)

Respondents.

Date Filed: November 24, 1986

ORDER

On September 26, 1986, the petitioner filed a Motion to Vacate the

Court’s Order dated August 7, 1986.

The record in this case reflects that on July 7, 1986 respondent filed a

Motion to Dismiss for Lack of Jurisdiction and to Strike as to the Taxable

Years 1979, 1980, 1981, and 1983 upon the ground that no statutory notice

of deficiency had been issued for said years. Petitioner on July 29, 1986

filed an objection to respondent’s motion, however, petitioner failed to

establish that statutory notices of deficiency had been issued for those years.

The Court thereupon granted respondent’s motion.

Petitioner attached to his motion to vacate a copy of a notice of deficiency

dated July 21, 1983, for petitioner’s 1981 tax year, and a notice of deficiency

for petitioner’s 1983 tax year. The date on the notice of deficiency, for the

tax year 1983 was illegible, in part, and the Court on October 28, 1986,

issued an order to respondent to provide the Court evidence with respect to

the date the notice of deficiency was mailed to petitioner.

On November 20, 1986 respondent filed an Objection to petitioner’s

pending motion to vacate, and attached thereto a copy of the notice of

deficiency for the taxable year 1983 which was mailed to petitioner on

September 3, 1986. —

The petition in this case which was filed on May 19, 1986, was not

commenced within the statutory 90-day period from the notice of deficiency

issued on July 21, 1983, as to the taxable year 1981. Further, this Court

does not have jurisdiction in a deficiency case unless the Commissioner first

Appendix E

25

issues a notice of deficiency to the taxpayer and the taxpayer then timely

files a petition with this Court. Therefore, the petition filed on May 19,

1986 cannot be considered a request to redetermine petitioner’s income tax

liabilities for the taxable year 1983 since such petition was filed prior to the

issuance of the notice of deficiency.

Petitioner has failed to show that notices of deficiency were ever issued

to him for the taxable years 1979 and 1980. Accordingly, it is

ORDERED that petitioner’s Motion to Vacate the Court’s Order dated

August 7, 1986, is denied.

Stamped /s/ Chief Judge

¢ Samuel B. Sterrett

26

UNITED STATES TAX COURT

No. 14576-86

Carlyn M. and Carol J. Johnson

(C-Me-J Enterprises)

Appellants,

Vv.

Commissioner of Internal Revenue

(Internal Revenue Service)

Respondents.

NOTICE OF APPEAL

Notice is hereby given that Carlyn M. and Carol J. Johnson/C-Me-J

Enterprises hereby appeals to the United States Court of Appeals for the

Eighth (8th) Circuit from Court Order of Judge Samuel B. Sterrett dated -

November 24, 1986.

Also, the Court Order dated October 28, 1986 from Judge Samuel B.

Sterrett and all references made regarding the ‘Motion to Appeal to the

Appeals Court/Objection to U.S. Tax Court’s Court Order’ filed by petitioner

on September 25, 1986 and including all papers filed by petitioner regarding

this Motion were supposed to be treated as a Notice of Appeal instead of a

Motion to Vacate. Therefore, this corresporidance is a Notice that all the

Motions to Appeal to the Appeals Court/Objection to the Tax Court’s Court

Order filed previously should be changed to Notices of Appeal to Court of

Appeals and all references made therein pertain directly and are part of this

‘Notice of Appeal to Court of Appeals’.

We are, therefore, resubmitting the previous correspondance by filing

this Notice of Appeal to Court of Appeals and are sending a check of $65.00

- Court Cost.

Sincerely,

C-Me-J Enterprises

/s/ Carlyn M. Johnson & Carol J. Johnson

|Dated: December 7, 1986]

Appendix F

27

MISCELLANEOUS STATEMENT

All other Opinions, Orders, etc. involved in this case are too voluminous

that it is necessary to see all the original previous filings if it is necessary

for review.

Also, please note that on the order dated April 10. 1987, where it states

that where ‘the Petitioners’ argument and contention that these requirements

are inapplicable because the Tax Court lacked jurisdiction are frivolous and

specious and requires no further comment’ that they did previously admit

that they did not base this comment on the Merits (Contents) of the Appellants

Brief.

Appendix G

28

CERTIFICATE OF SERVICE

I, , a notary public, do

hereby certify that on this day of :

1987 personally appeared before me, Carlyn M. (Carl) and Carol J. Johnson,

who, being by me first duly sworn declared that they are Pro-Se for the

foregoing Petition for Writ of Certiorari/Petition for Writ of Certiorari Before

Judgment and that the foregoing Petition for Writ of Certiorari/Petition for

Writ of Certiorari Before Judgment will be served upon Roger M. Olsen,

Assistant Attorney General and Michael L. Paup, Chief, Appellate Section

by certified mail, Receipt No. P-470 140 016 at Department of Justice-Tax

Division-Post Office Box 502-Washington, D.C. 20044 and on The Solicitor

General by certified mail, Receipt No. P-470 140 017 at Department of

Justice, Washington, D.C. 20530; and 40 copies of the foregoing Petition

for Writ of Certiorari/Petition for Writ of Certiorari Before Judgment will

be served upon the Supreme Court of the United States by express mail,

Receipt No. B98424406 at the Office of the Clerk-Supreme Court of the

United States-Washington, D.C. 20543.

My commission expires _

(Notorial Seal)

Notary Signature

Carlyn M. Johnson and Carol J. Johnson

Pro-Se

11987 Brookmont Drive

Maryland Heights, Missouri 63043

(314) 739-8326