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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Las Vegas, Nevada, at the time he
filed the petition in this case.
Petitioner timely filed Form 1040EZ, Income Tax Return for
Single and Joint Filers With No Dependents (return), for each of
his taxable years 1996 (1996 return) and 1997 (1997 return). In
each of those returns, petitioner reported total income of $0 and
total tax of $0. Above his respective signatures appearing in
his 1996 return and his 1997 return, petitioner printed the
following: “I AM NOT SIGNING THIS VOLUNTARILY”. Petitioner
attached a document to each of his returns for 1996 and 1997
(petitioner’s attachments to his 1996 and 1997 returns) that
contained statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless.2
On December 4, 1998, respondent issued to petitioner a
notice of deficiency (notice) with respect to his taxable year
1996 and a separate notice with respect to his taxable year 1997,
both of which he received. In the notice relating to peti-
tioner’s taxable year 1996, respondent determined a deficiency
2Petitioner’s attachments to his 1996 and 1997 returns are
similar to the documents that certain other taxpayers with cases
in the Court attached to their Federal income tax (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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Last modified: May 25, 2011