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respondent’s inclusion in petitioner’s gross income of $27,795 of
capital gain and $317 of interest received from Washington Mutual
Bank, FA. For both years, respondent describes the section
6651(a)(1) addition to tax as being determined on account of
petitioner’s delinquency in filing his tax return and the section
6654(a) addition to tax as being determined on account of
petitioner’s failure to pay sufficient estimated tax.
Petitioner filed a petition in which he assigned error to
respondent’s determinations of deficiencies of $16,067 and $3,299
for 1998 and 1999, respectively (the deficiencies), claiming: “I
do not owe that to the IRS. The IRS numbers are phony.” The
petition does not set forth any facts on which petitioner bases
his assignment of error. Because of irregularities in the
petition, and because he had failed to pay the required filing
fee, petitioner was ordered to file a proper petition and pay the
required fee. Subsequently, petitioner paid the fee and filed an
amended petition, in which he set forth his prayer for relief as
follows: “The Court decide that the IRS numbers are wrong,
because they are. I don’t know where their numbers come from.”
Like the petition, the amended petition does not set forth any
facts on which petitioner bases his assignment of error. In
neither the petition nor the amended petition (without
distinction, the petition) does petitioner assign error to
respondent’s determinations of the additions to tax for 1998 and
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