- 2 - motion. Background The record establishes and/or the parties do not dispute the following. Petitioners resided in Las Vegas, Nevada, at the time they filed the petition in this case. On April 15, 1999, petitioners filed jointly a Federal income tax (tax) return for their taxable year 1998 (1998 joint return). In their 1998 joint return, petitioners reported total income of $0, total tax of $0, and claimed a refund of $915.18 of tax withheld. Petitioners attached to their 1998 joint return Form W-2, Wage & Tax Statement, reporting wages, tips, and other compensation of $24,724.88. Petitioners also attached a document to their 1998 joint return (petitioners’ attachment to their 1998 joint return) that contained statements, contentions, and argu- ments that the Court finds to be frivolous and/or groundless.2 On July 14, 2000, respondent issued to petitioners a notice of deficiency (notice) with respect to their taxable year 1998, which they received. In that notice, respondent determined a deficiency in, and an accuracy-related penalty under section 6662(a) on, petitioners’ tax for their taxable year 1998 in the 2Petitioners’ attachment to their 1998 joint return is very similar to the documents that certain other taxpayers with cases in the Court attached to their tax returns. See, e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C. Memo. 2003-45.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011