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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Harleysville, Pennsylvania, at the
time he filed the petition in this case.
On or about April 11, 2000, petitioner filed a Federal
income tax (tax) return for his taxable year 1999 (1999 return).
In his 1999 return, petitioner reported total income of $0 and
total tax of $0 and claimed a refund of $4,168.99 of tax with-
held.2 Petitioner attached to his 1999 return Form W-2, Wage and
Tax Statement, reporting wages, tips, and other compensation of
$58,436.12. Petitioner also attached a document to his 1999
return (petitioner’s attachment to his 1999 return) that con-
tained statements, contentions, arguments, and requests that the
Court finds to be frivolous and/or groundless.3
On July 29, 2002, respondent issued to petitioner a notice
2Respondent treated petitioner’s 1999 return as a “math
error” return under sec. 6213(b)(2)(A) and issued a “math error”
letter to petitioner. Thereafter, although respondent had not
issued a notice of deficiency to petitioner with respect to his
taxable year 1999, respondent assessed a tax of $11,038 for that
year. An officer with respondent’s Appeals Office determined
that respondent improperly assessed the tax of $11,038 for
petitioner’s taxable year 1999, and respondent abated that tax.
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 respective returns. See, e.g., Copeland
v. Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.
Memo. 2003-45.
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Last modified: May 25, 2011