- 3 - Petitioner failed to file timely Federal income tax returns for 1991, 1992, and 1993. Respondent prepared a Substitute for Return for each year pursuant to section 6020(b), and, on November 9, 1995, respondent mailed to petitioner a notice of deficiency for all taxable years. See Swanson v. Commissioner, 121 T.C. 111, 112 n.1 (2003). Petitioner and his spouse subsequently filed joint returns in 2000 for the taxable years 1991, 1992, and 1993. Petitioner and his spouse reported total income of “$0” and a total tax of “$0” on all of the returns. The Hollidays also attached a lengthy document to each of the returns that contained arguments that this Court has repeatedly found to be frivolous and/or groundless, see, e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C. Memo. 2003-45, and we find this also to be true in this case. See also Holliday v. Commissioner, T.C. Memo. 2002-67, affd. 57 Fed. Appx. 774 (9th Cir. 2003). On February 17, 2003, respondent issued to petitioner a letter entitled “Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320” relating to petitioner’s unpaid tax liabilities for the aforementioned years. On March 22, 2003, petitioner submitted Form 12153, Request for a Collection Due Process Hearing, and attached a document which stated in part: Notice of Lien - Explanation for Disagreement Income. (1) There was a failure to determine a deficiency; (2) There was a failure to issue a Notice ofPage: Previous 1 2 3 4 5 6 7 8 9 Next
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