Arlene Williams - Page 2




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                                    Background                                        
               The record establishes and/or the parties do not dispute the           
          following.                                                                  
               Petitioner resided in Las Vegas, Nevada, at the time she               
          filed the petition in this case.                                            
               On January 11, 1998, petitioner filed late a Federal income            
          tax (tax) return for her taxable year 1996 (1996 return).  In her           
          1996 return, petitioner reported total income of $0 and total tax           
          of $0.  Petitioner attached a document to her 1996 return (peti-            
          tioner’s attachment to her 1996 return) that contained state-               
          ments, contentions, and arguments that the Court finds to be                
          frivolous and/or groundless.2                                               
               On December 11, 1998, respondent issued to petitioner a                
          notice of deficiency (notice) with respect to her taxable year              
          1996, which she received.  In that notice, respondent determined            
          a deficiency in, an addition under section 6651(a)(1)3 to, and an           
          accuracy-related penalty under section 6662(a) on, petitioner’s             
          tax for her taxable year 1996 in the respective amounts of                  
          $5,474, $1,369, and $1,095.                                                 


               2Petitioner’s attachment to her 1996 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.                                                              
               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.                                      




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