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penalty under section 6662(a)2 on, petitioner’s tax for 1999 in
the respective amounts of $9,823 and $1,965. We shall grant
respondent’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Las Vegas, Nevada, at the time he
filed the petition in this case.
On or about April 17, 2000, petitioner filed a Federal
income tax (tax) return for his taxable year 1999 (1999 return).
In that return, petitioner claimed his filing status was single
and reported total income of $0 and total tax of $0. Petitioner
attached a document to his 1999 return (petitioner’s attachment
to his 1999 return) that contained statements, contentions, and
arguments that the Court finds to be frivolous and/or ground-
less.3
On January 25, 2002, respondent issued to petitioner a
2All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
3Petitioner’s attachment to his 1999 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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