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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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