Roger Stoewer - Page 3




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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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