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section 66731 (respondent’s motion).2 We shall grant respon-
dent’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioners resided in Henderson, Nevada, at the time they
filed the petition in this case.
On April 15, 1999, petitioners filed jointly a Federal
income tax (tax) return for their taxable year 1998 (1998 joint
return). In their 1998 joint return, petitioners reported total
income of $0 and total tax of $0 and claimed a refund of $748.40
of tax withheld. Petitioners attached to their 1998 joint return
Form W-2, Wage and Tax Statement, reporting wages, tips, and
other compensation of $73,382.39. Petitioners also attached a
document to their 1998 joint return (petitioners’ attachment to
their 1998 joint return) that contained statements, contentions,
and arguments that the Court finds to be frivolous and/or ground-
less.3
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
2Although the Court ordered petitioners to file a response
to respondent’s motion, petitioners failed to do so.
3Petitioners’ attachment to their 1998 joint return is very
similar to the documents that certain other taxpayers with cases
in the Court attached to their tax returns. See, e.g., Copeland
(continued...)
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