- 2 - Background The record establishes and/or the parties do not dispute the following. Petitioner resided in Long Beach, California, at the time he filed the petition in this case. On January 9, 2006, petitioner filed a petition with respect to the notice of deficiency (notice) which respondent issued to him for his taxable year 2003 and in which respondent determined a deficiency in, and an accuracy-related penalty under section 6662(a) on, petitioner’s Federal income tax (tax) for that year of $69,348 and $13,870, respectively. The petition contains statements, contentions, and arguments that the Court finds to be frivolous and/or groundless. For example, the petition states in pertinent part: Petitioner’s fundamental claim is that the entire “deficiency” notice is invalid as a matter of law, because: (1) the alleged “deficiency” at issue is, in reality, Petitioner’s “total” alleged tax liability for 2003; (2) the alleged “deficiency” was determined without making a determination that a prior, 6201 assessment, was “imperfect and incomplete”; (3) Respondent has no tax return showing a “tax due” greater than the “zero” amount shown on Petitioner’s 2003 income tax return; and (3) no statutes makes Petitioner “liable” for the income taxes at issue. [Reproduced literally.] 1(...continued) effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011