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motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Las Vegas, Nevada, at the time he
filed the petition in this case.
On or about October 15, 1998, petitioner filed a Federal
income tax (tax) return for his taxable year 1997 (1997 return).
In his 1997 return, petitioner reported total income of $0, total
tax of $0, and claimed a refund of $560 of tax withheld. Peti-
tioner attached to his 1997 return five Forms W-2, Wage and Tax
Statement (Form W-2), reporting wages, tips, and other compensa-
tion totaling $29,977.42. Petitioner also attached a document to
his 1997 return (petitioner’s attachment to his 1997 return) that
contained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.2
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, total tax of $0, and
claimed a refund of $1,830.69 of tax withheld. Petitioner
attached to his 1998 return three Forms W-2 reporting wages,
2Petitioner’s attachment to his 1997 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 v.
Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.
Memo. 2003-45.
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