Robert Holliday - Page 3

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               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 of               





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