G. Robert Lyman and Shari Lee Wright Lyman - Page 3




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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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