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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.
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Last modified: May 25, 2011