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of deficiency (notice of deficiency) with respect to his taxable
year 1999, which he received. In that notice, respondent deter-
mined a deficiency in, and an accuracy-related penalty under
section 6662(a) on, petitioner’s tax for his taxable year 1999 in
the respective amounts of $11,038 and $2,207.60.4
Petitioner did not file a petition in the Court with respect
to the notice of deficiency relating to his taxable year 1999.
Instead, on October 22, 2002, in response to the notice of
deficiency, petitioner sent a letter (petitioner’s October 22,
2002 letter) to the Internal Revenue Service (IRS) that contained
statements, contentions, arguments, and requests that the Court
finds to be frivolous and/or groundless.5
On February 3, 2003, respondent assessed petitioner’s tax
for his taxable year 1999.6 (We shall refer to that unpaid
assessed amount, as well as interest as provided by law, as
petitioner’s unpaid liability for 1999.)
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
4Thereafter, respondent conceded that petitioner is not
liable for the accuracy-related penalty under sec. 6662(a).
5Petitioner’s October 22, 2002 letter is very similar to the
types of letters that certain other taxpayers with cases in the
Court sent to the IRS in response to the respective notices of
deficiency that respondent issued to them. See, e.g., Copeland
v. Commissioner, supra; Smith v. Commissioner, supra.
6See supra note 4.
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