- 3 - in, and an accuracy-related penalty under section 6662(a)3 on, petitioner’s tax for that year in the respective amounts of $3,775 and $465. In the notice relating to petitioner’s taxable year 1997, respondent determined a deficiency in, and an accuracy-related penalty under section 6662(a) on, petitioner’s tax for that year in the respective amounts of $4,069 and $813. Petitioner did not file a petition in the Court with respect to the notice relating to his taxable year 1996 or the notice relating to his taxable year 1997. Instead, on January 12, 1999, in response to each such notice, petitioner sent a separate letter (collectively, petitioner’s January 12, 1999 letters) to the Internal Revenue Service that contained statements, conten- tions, arguments, and requests that the Court finds to be frivo- lous and/or groundless.4 On May 24, 1999, respondent assessed petitioner’s tax, as well as any penalties and interest as provided by law, for each of his taxable years 1996 and 1997. (We shall refer to those assessed amounts, as well as interest as provided by law accrued after May 24, 1999, as petitioner’s unpaid liability for each of 3All section references are to the Internal Revenue Code in effect at all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure. 4Petitioner’s January 12, 1999 letters are similar to the letters that certain other taxpayers with cases in the Court sent to the Internal Revenue Service in response to the notices issued to them. See, e.g., Copeland v. Commissioner, supra; Smith v. Commissioner, supra.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011