MEMORANDUM OPINION
HAINES, Judge:
This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121 and to impose a penalty under section 6673.
Background
At the time of the filing of the petition, petitioner resided in San Jose, California.
On his 1999 tax return, petitioner reported zero income and requested a full refund of all taxes withheld. Petitioner...
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