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each of his taxable years 1988 and 1989. (We shall refer to
those assessed amounts, as well as interest as provided by law
accrued after February 21, 1994, as petitioner’s unpaid liability
for each of his taxable years 1988 and 1989.)
On February 21, 1994, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ity for each of his taxable years 1988 and 1989. On March 28,
1994, respondent issued a second notice of balance due with
respect to each such unpaid liability.
On July 31, 1997, respondent issued to petitioner a notice
of deficiency (July 31, 1997 notice) with respect to his taxable
years 1993, 1994, and 1995, which he received. In that notice,
respondent determined a deficiency in, and additions to tax under
sections 6651(a)(1) and 6654 on, petitioner’s tax for each of his
taxable years 1993, 1994, and 1995.
Petitioner did not file a petition in the Court with respect
to the July 31, 1997 notice relating to his taxable years 1993,
1994, and 1995. Instead, on September 9, 1997, in response to
the July 31, 1997 notice, petitioner sent a letter (petitioner’s
September 9, 1997 letter) to the Internal Revenue Service that
contained statements, contentions, arguments, and requests that
the Court finds to be frivolous and/or groundless.2
2Petitioner’s September 9, 1997 letter is the type of letter
that is similar to the types of letters that certain other
(continued...)
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