- 3 -
tips, and other compensation totaling $34,719. Petitioner also
attached a document to that return (petitioner’s attachment to
his 1998 return) that contained statements, contentions, and
arguments that the Court finds to be frivolous and/or ground-
less.3
On July 2, 1999, and February 11, 2000, respectively,
respondent issued to petitioner notices of deficiency with
respect to his taxable years 1997 and 1998, which he received.
In the notice of deficiency (notice) relating to petitioner’s
taxable year 1997, respondent determined a deficiency in, an
addition under section 6651(a)(1) to, and an accuracy-related
penalty under section 6662 on, petitioner’s tax for that year in
the respective amounts of $5,273, $1,178.25, and $942.60. In the
notice relating to petitioner’s taxable year 1998, respondent
determined a deficiency in, and an accuracy-related penalty under
section 6662 on, petitioner’s tax for that year in the respective
amounts of $4,482 and $530.26.
Petitioner did not file a petition in the Court with respect
to the notice relating to his taxable year 1997. Instead, on
July 15, 1999, in response to the notice with respect to peti-
tioner’s taxable year 1997, petitioner sent a letter (peti-
3Petitioner’s attachment to his 1998 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, supra; Smith v. Commissioner, supra.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011