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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.
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