Brian Hilvety - Page 3

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          wages Federal income tax, FICA tax, and Medicare tax of $2, $962,           
          and $225, respectively.                                                     
               During 1997, World of Powersports, Inc., paid petitioner               
          wages of $38.  That company withheld from those wages FICA tax of           
          $2.                                                                         
               During 1997, petitioner did not make any estimated tax                 
          payments to the Internal Revenue Service.                                   
               Petitioner did not file a tax return for his taxable year              
          1997.                                                                       
               On January 31, 2002, petitioner filed the petition in this             
          case.  The petition contains allegations, contentions, arguments,           
          and questions that the Court finds to be frivolous and/or ground-           
          less.                                                                       
               On March 7, 2003, respondent submitted respondent’s trial              
          memorandum in this case.  Attached to respondent’s trial memoran-           
          dum was a copy of a draft of a stipulation of facts proposed by             
          petitioner (petitioner’s proposed stipulation of facts) as well             
          as petitioner’s cover letter dated February 28, 2003, transmit-             
          ting such proposed stipulation of facts to respondent’s counsel             
          (petitioner’s February 28, 2003 transmittal letter).                        
               In an Order dated March 10, 2003 (March 10, 2003 Order), the           
          Court ordered respondent’s trial memorandum, including the                  
          attachments thereto, to be filed as of the date of receipt by the           
          Court.  In that Order, the Court found that certain statements              






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