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On or about August 26, 1996, respondent received from
petitioner his joint Federal income tax return for 1995.
Petitioner reported negative taxable income and no tax due.
On or about April 15, 1997, respondent received from
petitioner his joint Federal income tax return for 1996.
Petitioner listed his income tax liability as $4,040. This
liability was attributable to one of petitioner’s children ($73
reported on Form 8814), whose income tax liability petitioner
elected to report on petitioner’s return, and to self-employment
tax ($3,967). Petitioner reported zero taxable income.
On or about April 15, 1998, respondent received from
petitioner his joint Federal income tax return for 1997.
Petitioner listed his income tax liability as $8,121. This
liability was attributable to one of petitioner’s children ($98
reported on Form 8814), whose income tax liability petitioner
elected to report on petitioner’s return, and to self-employment
tax ($8,023). Petitioner reported zero taxable income.
On June 3, 1999, respondent sent petitioner a statutory
notice of deficiency for 1994. Respondent determined a $5,387
deficiency and a $1,077.40 penalty pursuant to section 6662(a)
for 1994. Petitioner received this notice of deficiency and
responded to it with a 15-page letter containing frivolous and
groundless arguments.
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