Randy S. Quigley - Page 3

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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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