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frivolous and/or groundless.5
On April 13, 1997, petitioners mailed to respondent Form
1040 for their taxable year 1996 (1996 Form 1040). Above their
signatures appearing in their 1996 Form 1040, petitioners struck
from the jurat clause the words “Under penalties of perjury”.
Because petitioners struck those words, respondent concluded that
petitioners’ 1996 Form 1040 was not a valid tax return.6
In their 1996 Form 1040, petitioners reported total income
of $0 and total tax of $0. Petitioners attached a document to
their 1996 Form 1040 (petitioners’ attachment to their 1996 Form
1040) that contained statements, contentions, and arguments that
the Court finds to be frivolous and/or groundless.7
On March 27, 1998, respondent issued to petitioner Daniel
Holguin (Mr. Holguin) a separate notice of deficiency (notice)
with respect to each of his taxable years 1994, 1995, and 1996,
all of which he received. In the notice with respect to Mr.
Holguin’s taxable year 1994, respondent determined a deficiency
5Petitioners’ attachment to their 1995 Form 1040 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.
6On Jan. 15, 1998, respondent prepared a separate substitute
for return for each petitioner with respect to the taxable year
1996.
7Petitioners’ attachment to their 1996 Form 1040 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.
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Last modified: May 25, 2011