Mary K. Dues - Page 3

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          payments of $0, and tax owed of $0.                                         
               In Part II, Explanation of Changes to Income, Deductions,              
          and Credits, of each of the amended tax returns for 1997 and 1998           
          and in an attachment to each such amended tax return, the expla-            
          nation that petitioner and Mr. Dues gave for amending the 1997              
          return and the 1998 return (explanation for the amended 1997                
          return and for the amended 1998 return) contained statements,               
          contentions, arguments, and requests that the Court finds to be             
          frivolous and/or groundless.2                                               
               On September 20, 2000, respondent issued a notice of defi-             
          ciency (notice) to petitioner and Mr. Dues in which respondent              
          determined the following deficiencies in, and accuracy-related              
          penalties under section 6662(a)3 on, the tax of petitioner and              
          Mr. Dues for each of the taxable years 1997 and 1998:                       
                                           Accuracy-Related Penalty                   
                 Year      Deficiency       Under Sec. 6662(a)                        
                 1997       $41,648                  $8,330                           
                 1998       3,821                    764                              



               2The explanation for the amended 1997 return and for the               
          amended 1998 return contained statements, contentions, arguments,           
          and requests that are very similar to the types of statements,              
          contentions, arguments, and requests contained in 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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