G. Robert Lyman and Shari Lee Wright Lyman - Page 2




                                        - 2 -                                         
          respondent’s motion.                                                        
                                     Background                                       
               The record establishes and/or the parties do not dispute the           
          following.                                                                  
               Petitioners’ mailing address was in Moapa, Nevada, at the              
          time they filed the petition in this case.                                  
               On or about April 14, 1998, petitioners filed jointly a                
          Federal income tax (tax) return for their taxable year 1997 (1997           
          joint return).  In their 1997 joint return, petitioners reported            
          total income of $0, total tax of $0, and claimed a refund of                
          $1,102.51 of tax withheld.  Petitioners attached to their 1997              
          joint return two Forms W-2, Wage and Tax Statement, reporting               
          wages, tips, and other compensation totaling $47,639.38.  Peti-             
          tioners 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.2                                   
               On April 15, 1999, petitioners filed jointly a tax return              
          for their taxable year 1998 (1998 joint return).  In their 1998             
          joint return, petitioners reported total income of $0 and total             
          tax of $0.  Petitioners attached a document to their 1998 joint             

               2Petitioners’ 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, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.            
          Memo. 2003-45.                                                              





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