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following.
Petitioners resided in Las Vegas, Nevada, at the time they
filed the petition in this case.
On or before April 1, 1998, petitioners filed jointly a
Federal income tax (tax) return for their taxable year 1997 (1997
joint return). In their 1997 joint return, petitioners reported
total income of $0, total tax of $0, and claimed a refund of
$5,839.56 of tax withheld. Petitioners attached to their 1997
joint return Form W-2, Wage and Tax Statement, reporting wages,
tips, and other compensation of $78,556.14 and two Forms 1099-
MISC, Miscellaneous Income, reporting other income totaling
$7,600. Petitioners also attached a document to their 1997 joint
return (petitioners’ attachment to their 1997 joint return) that
contained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.1
On October 7, 1999, respondent applied a payment of $35.96
to petitioners’ account with respect to their taxable year 1997.
On November 17, 1999, respondent issued to petitioners a
notice of deficiency (notice) with respect to their taxable year
1997, which they received. In that notice, respondent determined
a deficiency in, and an accuracy-related penalty under section
1Petitioners’ attachment to their 1997 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
v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.
Memo. 2003-45.
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