- 2 -
is no dispute as to a material fact and that respondent is
entitled to judgment as a matter of law.
Background2
Petitioner, a retired Federal employee, is inveterately
opposed to paying Federal income taxes. In Lee v. Commissioner,
T.C. Memo. 2002-95, affd. 61 Fed. Appx. 471 (9th Cir. 2003), we
observed that petitioner failed to file Federal income tax
returns for 1995, 1996, 1997, and 1998, and we sustained the
Commissioner’s determinations that petitioner was liable for
deficiencies and additions to tax for each of those taxable
years. In addition, we imposed a penalty upon petitioner
pursuant to section 6673(a) in the amount of $10,000 on the
ground that his arguments were meritless and asserted solely for
purpose of delay.3
The record in the present case includes a Form 4340
(Certificate of Assessments, Payments, and Other Specified
Matters) which demonstrates that, on September 9, 2002,
respondent entered assessments against petitioner for the taxable
year 1995 reflecting the tax deficiency, additions to tax, and
penalty under section 6673(a) set forth in the Court’s decision
at docket No. 6655-00, as well as statutory interest. On
2 The record reflects and/or the parties do not dispute the
following facts.
3 The Court entered its decision at docket No. 6655-00 on
Apr. 10, 2002.
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