Gary James Copeland - Page 4




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               the legal definition of “income”, if I were to swear to                
               having received any other amount of “income”, I would                  
               be committing perjury * * *.  So, not wishing to commit                
               perjury * * * I can only swear to having “zero” income                 
               for 1997.  [Reproduced literally.]                                     
               On or about April 15, 1999, petitioner filed a tax return              
          for his taxable year 1998 (1998 return).  In his 1998 return,               
          petitioner reported total income of $0 and total tax of $0.                 
          Petitioner attached a three-page document to his 1998 return                
          (petitioner’s attachment to his 1998 return), which was very                
          similar to petitioner’s attachment to his 1997 return.                      
               On August 3, 2000, respondent issued to petitioner a notice            
          of deficiency (notice) with respect to his taxable years 1997 and           
          1998, which he received.  In that notice, respondent determined a           
          deficiency in, and an accuracy-related penalty under section 6662           
          on, petitioner’s tax (1) for his taxable year 1997 in the respec-           
          tive amounts of $2,104 and $421 and (2) for his taxable year 1998           
          in the respective amounts of $2,021 and $404.                               
               Petitioner did not file a petition in the Court with respect           
          to the notice relating to his taxable years 1997 and 1998.                  
          Instead, on October 30, 2000, in response to the notice, peti-              
          tioner sent a letter (petitioner’s October 30, 2000 letter) to              
          the Internal Revenue Service.  That letter stated in pertinent              
          part:                                                                       
                         Your Deficiency Notice dated August 3, 2000                  
                    According to your “Deficiency Notice” of above                    
               date (cover sheet [page 1 of notice with respect to                    





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