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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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Last modified: May 25, 2011