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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.
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