Deborah Carman Goodin - Page 8

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          the notice of determination relating to petitioner’s unpaid                 
          liabilities for 1997, 1998, and 1999.  The attachment to the                
          petition (petitioner’s attachment to the petition) that we                  
          consider to be part of the petition contained statements, conten-           
          tions, arguments, and requests that the Court finds to be frivo-            
          lous and/or groundless.2                                                    
               On or about November 11, 2004, after petitioner filed her              
          petition with the Court, petitioner sent to respondent a document           
          entitled “Notice Of Response In The Form Of an Affidavit Under 5            
          USC” (petitioner’s November 11, 2004 affidavit).  Petitioner’s              
          November 11, 2004 affidavit contained statements, contentions,              
          arguments, and requests that the Court finds to be frivolous                
          and/or groundless.3                                                         
               In response to petitioner’s November 11, 2004 affidavit,               
          respondent sent a letter to petitioner dated January 11, 2005               


               2The frivolous and/or groundless statements, contentions,              
          arguments, and requests in petitioner’s attachment to the peti-             
          tion are similar to the frivolous and/or groundless statements,             
          contentions, arguments, and requests in petitions filed by                  
          certain other taxpayers with cases in the Court.  See, e.g.,                
          Jones v. Commissioner, T.C. Memo. 2003-131; Copeland v. Commis-             
          sioner, T.C. Memo. 2003-46.                                                 
               3Petitioner’s November 11, 2004 affidavit contained state-             
          ments, contentions, arguments, and requests that are similar to             
          the types of statements, contentions, arguments, and requests               
          contained in the documents that certain other taxpayers with                
          cases in the Court have sent to the Internal Revenue Service.               
          See, e.g., Copeland v. Commissioner, supra; Smith v. Commis-                
          sioner, T.C. Memo. 2003-45.                                                 






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