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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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