- 11 -
determined, inter alia, that the total tax of $4,024 reported in
petitioner’s 1996 filed return was understated and that peti-
tioner has a deficiency of $2,617 for that year. On June 26,
2002, petitioner filed a petition with respect to the notice of
deficiency relating to petitioner’s taxable years 1996 and 1997,
and on September 16, 2002, petitioner filed an amended petition
in that case (docket No. 10753-02).
On March 10, 2003, petitioner submitted a document to the
Court entitled “Trial Memorandum for Petitioner” that the Court
had filed (petitioner’s trial memorandum). Petitioner’s trial
memorandum contained questions, statements, contentions, and
arguments that the Court found in an Order dated March 17, 2003
(March 17, 2003 Order) to be frivolous and/or groundless. In the
Court’s March 17, 2003 Order, the Court reminded petitioner about
section 6673(a)(1) and informed him that if he continued to
advance frivolous and/or groundless questions, statements,
contentions, and/or arguments, the Court would be inclined to
impose a penalty on him under section 6673(a)(1).
OPINION
A taxpayer may raise challenges to the existence or the
amount of the taxpayer’s underlying tax liability if the taxpayer
did not receive a notice of deficiency or did not otherwise have
an opportunity to dispute the tax liability. Sec. 6330(c)(2)(B).
Where the validity of the underlying tax liability is properly
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011