- 8 - the notice of determination relating to petitioner’s unpaid liabilities for 1997, 1998, and 1999. The attachment to the petition (petitioner’s attachment to the petition) that we consider to be part of the petition contained statements, conten- tions, arguments, and requests that the Court finds to be frivo- lous and/or groundless.2 On or about November 11, 2004, after petitioner filed her petition with the Court, petitioner sent to respondent a document entitled “Notice Of Response In The Form Of an Affidavit Under 5 USC” (petitioner’s November 11, 2004 affidavit). Petitioner’s November 11, 2004 affidavit contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.3 In response to petitioner’s November 11, 2004 affidavit, respondent sent a letter to petitioner dated January 11, 2005 2The frivolous and/or groundless statements, contentions, arguments, and requests in petitioner’s attachment to the peti- tion are similar to the frivolous and/or groundless statements, contentions, arguments, and requests in petitions filed by certain other taxpayers with cases in the Court. See, e.g., Jones v. Commissioner, T.C. Memo. 2003-131; Copeland v. Commis- sioner, T.C. Memo. 2003-46. 3Petitioner’s November 11, 2004 affidavit contained state- ments, contentions, arguments, and requests that are similar to the types of statements, contentions, arguments, and requests contained in the documents that certain other taxpayers with cases in the Court have sent to the Internal Revenue Service. See, e.g., Copeland v. Commissioner, supra; Smith v. Commis- sioner, T.C. Memo. 2003-45.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011