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tioner’s July 15, 1999 letter) to the Internal Revenue Service
that contained statements, contentions, arguments, and requests
that the Court finds to be frivolous and/or groundless.4
Petitioner did not file a petition in the Court with respect
to the notice relating to his taxable year 1998.
On January 3, 2000, respondent assessed petitioner’s tax, as
well as an addition to tax, a penalty, and interest as provided
by law, for his taxable year 1997. On August 28, 2000, respon-
dent assessed petitioner’s tax, as well as a penalty and interest
as provided by law, for his taxable year 1998. (We shall refer
to those assessed amounts, as well as interest as provided by law
accrued after January 3, 2000, and August 28, 2000, respectively,
as petitioner’s unpaid liabilities for his taxable years 1997 and
1998.)
On January 3, 2000, and August 28, 2000, respectively,
respondent issued to petitioner notices of balance due with
respect to petitioner’s unpaid liabilities for his taxable years
1997 and 1998. On February 7, 2000, respondent issued a second
notice of balance due with respect to petitioner’s unpaid liabil-
ity for his taxable year 1997.
On April 4, 2001, respondent issued to petitioner a notice
4Petitioner’s July 15, 1999 letter is very similar to the
letters that certain other taxpayers with cases in the Court sent
to the Internal Revenue Service in response to the notices issued
to them. See, e.g., Copeland v. Commissioner, supra; Smith v.
Commissioner, supra.
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