- 2 - section 66731 (respondent’s motion).2 We shall grant respon- dent’s motion. Background The record establishes and/or the parties do not dispute the following. Petitioner resided in Toledo, Ohio, at the time he filed the petition in this case. On June 2, 2000, respondent received from petitioner a Federal income tax (tax) return for his taxable year 1999 (1999 return). In his 1999 return, petitioner reported total income of $0, total tax of $0, and claimed a refund of $2,777.49 of tax withheld. Petitioner attached to his 1999 return Form W-2, Wage and Tax Statement, reporting wages, tips, and other compensation totaling $49,643.38. Petitioner also attached a document to his 1999 return (petitioner’s attachment to his 1999 return) that contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.3 1All 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. 2Although the Court ordered petitioner to file a response to respondent’s motion, petitioner failed to do so. 3Petitioner’s attachment to his 1999 return is very similar to the documents that certain other taxpayers with cases in the Court attached to their tax returns. See, e.g., Flathers v. Commissioner, T.C. Memo. 2003-60; Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C. Memo. 2003-45.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011