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return (petitioners’ attachment to their 1998 joint return) that
contained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.3
On February 18, 2000, respondent issued to petitioners a
notice of deficiency (notice) with respect to their taxable year
1997, and on March 10, 2000, respondent issued to them a notice
with respect to their taxable year 1998, both of which they
received. In the notice relating to petitioners’ taxable year
1997, respondent determined a deficiency in, and an accuracy-
related penalty under section 6662(a) on, petitioners’ tax for
that year in the respective amounts of $6,452.10 and $1,069.92.
In the notice relating to petitioners’ taxable year 1998, respon-
dent determined a deficiency in, and an accuracy-related penalty
under section 6662(a) on, petitioners’ tax for that year in the
respective amounts of $6,086 and $1,217.20.
Petitioners did not file a petition in the Court with
respect to the notice relating to their taxable year 1997 or the
notice relating to their taxable year 1998.
On July 31, 2000, and August 28, 2000, respectively, respon-
dent assessed petitioners’ tax, as well as any penalties and
interest as provided by law, for their taxable years 1997 and
3Petitioners’ attachment to their 1998 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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Last modified: May 25, 2011