George R. and Karen S. Kemper - Page 3

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          total tax of $0 and claimed a refund of $5,415.97 of tax with-              
          held.  Petitioners attached to their 1996 joint return four Forms           
          W-2 reporting wages, tips, and other compensation totaling                  
          $53,581.   Petitioners also attached a document to their 1996               
          joint return (petitioners’ attachment to their 1996 joint return)           
          that contained statements, contentions, and arguments that the              
          Court finds to be frivolous and/or groundless.3                             
               On or about April 15, 1998, petitioners filed jointly a tax            
          return for their taxable year 1997 (1997 joint return).  In their           
          1997 joint return, petitioners reported total income of $0 and              
          total tax of $0 and claimed a refund of $1,742.50 of tax with-              
          held.  Petitioners attached to their 1997 joint return Form W-2             
          reporting wages, tips, and other compensation of $60,124.                   
          Petitioners also attached a document to their 1997 joint return             
          (petitioners’ attachment to their 1997 joint return) that con-              
          tained statements, contentions, and arguments that the Court                
          finds to be frivolous and/or groundless.4                                   
               On or about April 14, 1999, petitioners filed jointly a tax            
          return for their taxable year 1998 (1998 joint return).  In their           

               3Petitioners’ attachment to their 1996 joint 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, supra; Smith v. Commissioner, supra.                       
               4Petitioners’ attachment to their 1997 joint 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, supra; Smith v. Commissioner, supra.                       





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