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exhibits contained the same types of statements, contentions,
arguments, and questions that petitioners set forth in
petitioners’ attachment to their 1996 Form 1040, petitioners’
attachment to their 1997 Form 1040A, petitioners’ attachment to
their 1996 Form 12153, petitioners’ attachment to their 1997 and
1999 Form 12153, and the various letters described above that
petitioners sent to the IRS with respect to their taxable years
1996, 1997, and 1999.
On May 29, 2003, the Court issued an Order (Court’s May 29,
2003 Order) in which, inter alia, the Court indicated that it had
reviewed the petition and the exhibits attached thereto and found
the petition and certain of those exhibits to contain statements,
contentions, arguments, and questions that the Court found to be
frivolous and/or groundless. In that Order, the Court reminded
petitioners about section 6673(a)(1).
OPINION
A taxpayer may raise challenges to the existence or the
amount of a taxpayer’s underlying tax liability if the taxpayer
did not receive a notice of deficiency or did not otherwise have
an opportunity to dispute the tax liability. Sec. 6330(c)(2)(B).
Where the validity of the underlying tax liability is properly
placed at issue, the Court will review the matter on a de novo
basis. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000).
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