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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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