John J. Delgado - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Altamonte Springs, Florida.                 
               Petitioner submitted to the Internal Revenue Service Forms             
          1040A, U.S. Individual Income Tax Return, for 1998, 1999, and               
          2000.  The Forms 1040A for 1998, 1999, and 2000 listed zeros for,           
          among other things, the amount of petitioner’s income, adjusted             
          gross income, taxable income, tax, total tax, and amount owed.              
          Attached to these Forms 1040A were frivolous and groundless                 
          arguments about why petitioner was not liable to pay tax.                   
          Respondent mailed petitioner statutory notices of deficiency for            
          1998, 1999, and 2000 on May 2, 2002, February 15, 2002, and                 
          February 15, 2002, respectively.  Petitioner received the                   
          statutory notices of deficiency for 1998, 1999, and 2000.                   
          Petitioner responded to each notice of deficiency with frivolous            
          and groundless arguments.  Petitioner, however, did not petition            
          the Court regarding the statutory notices of deficiency for 1998,           
          1999, and 2000.                                                             
               On September 30, 2002, February 17, 2003, and December 23,             
          2002, respondent assessed petitioner’s liabilities and mailed               
          petitioner notice and demand for payment for 1998, 1999, and                
          2000, respectively.                                                         






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