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tained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.4
In their amended 1998 joint return, petitioners reported
total income of $0 and total tax of $0 and claimed a refund of
$7,852 of tax withheld. In Part II, Explanation of Changes to
Income, Deductions, and Credits, of their amended 1998 joint
return, petitioners’ explanation for amending that return
(petitioners’ explanation for their amended 1998 joint return)
contained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.5
The Internal Revenue Service (IRS) determined that petition-
ers’ amended 1997 joint return and amended 1998 joint return were
frivolous and denied the refund claimed in each such amended
return.
On June 26, 2001, respondent issued to petitioners a notice
of Federal tax lien filing and your right to a hearing (notice of
4Petitioners’ explanation for amending their 1997 joint
return contained statements, contentions, and arguments that are
similar to the types of statements, contentions, and arguments
contained in 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. Commiss-
ioner, T.C. Memo. 2003-45.
5Petitioners’ explanation for amending their 1998 joint
return contained statements, contentions, and arguments that are
similar to the types of statements, contentions, and arguments
contained in 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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