CHIECHI, Judge: This case is before us on respondent's motion for summary judgment (respondent's motion). ¹ We shall grant respondent's motion.

The record establishes and/or the parties do not dispute the following.

Petitioner resided in Michigan at the time he filed the petition.

On November 14, 2006, a Federal grand jury for the U.S. District Court for the Eastern District of Michigan returned a four-count indictment (indictment) against petitioner. In that indictment, petitioner was charged with violating section 7201² by willfully attempting to evade and defeat Federal income tax (tax) for each of the years 1998 through 2001. The indictment charged that petitioner had the following unreported taxable income and 2013 Tax Ct. Memo LEXIS 59">*60 unpaid tax liabilities for those years:

*60 On May 22, 2008, after a trial in the U.S. District Court (criminal proceeding), a jury found petitioner guilty on all counts in the indictment. The U.S. District Court sentenced petitioner, inter alia, to 27 months' imprisonment with two years of supervised release.

On December 5, 2008, petitioner appealed his conviction to the U.S. Court of Appeals for the Sixth Circuit. On June 4, 2010, the Court of Appeals affirmed petitioner's conviction.

On April 23, 2010, respondent issued a notice of deficiency (notice) to petitioner. In that notice, respondent determined the following deficiencies in, additions to, and fraud penalties on petitioner's tax for petitioner's taxable years 1998 through 2002: ^{32013 Tax Ct. Memo LEXIS 59">*61}

*61 On September 2, 2011, we issued an Order granting respondent's motion for partial summary judgment. In that Order, we held that "petitioner is estopped from denying liability for the fraud additions to tax and penalties for 1998 through 2001."

On October 15, 2012, we issued an Order in which we ordered petitioner to file a response to respondent's motion. In that Order, we also indicated that our review of the record suggested that petitioner might intend to advance in this case frivolous and/or groundless statements, contentions, arguments and/or questions. We reminded petitioner in the Order dated October 15, 2012, about section 6673(a)(1) and admonished him that if he advanced frivolous and/or groundless statements, contentions, arguments, and/or questions and/or instituted or maintained this proceeding primarily for delay, we would impose on him a penalty under section 6673(a)(1) in an amount not exceeding $25,000.

We may grant summary judgment where there is no genuine dispute as to any material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518">98 T.C. 518, 98 T.C. 518">520 (1992), aff'd, 2013 Tax Ct. Memo LEXIS 59">*62 17 F.3d 965">17 F.3d 965 (7th Cir. 1994).

*62 In respondent's motion, respondent seeks summary adjudication that petitioner is liable for the following amounts ⁴ of deficiencies in, additions to, and fraud penalties on petitioner's tax for his taxable years 1998 through 2001: ⁵

¹ The respective amounts shown above for each of petitioner's taxable years 1998, 1999, and 2000 are less than the respective amounts that respondent determined in the notice for each of those taxable years. The amount of the addition to tax under sec. 6651(a)(1) for petitioner's taxable year 1999 that respondent determined in the notice was ($196).

The respective amounts of the deficiencies in petitioner's tax for his taxable years 1998 and 2000 with respect to which respondent 2013 Tax Ct. Memo LEXIS 59">*63 seeks summary adjudication equal the respective amounts of the unpaid tax liabilities that the indictment charged, and the jury agreed, petitioner had for those taxable years. The respective *63 amounts of the deficiencies in petitioner's tax for his taxable years 1999 and 2001 with respect to which respondent seeks summary adjudication are less than the respective amounts of the unpaid tax liabilities that the indictment charged, and the jury agreed, petitioner had for those years.

It is petitioner's position that there are genuine disputes of material fact that preclude us from granting respondent's motion. In support of that position, petitioner argues (petitioner's withholding credit argument) that his "employer" withheld tax from his wages during each of his taxable years 1998 through 2002 and that any deficiency in his tax for each of those taxable years must be determined by allowing him a credit for tax withheld for each such year.

We have jurisdiction to redetermine the correct amount of a deficiency where the Commissioner of Internal Revenue has issued a valid notice of deficiency and the taxpayer has timely filed a petition. E.g., Versteeg v. Commissioner, 91 T.C. 339">91 T.C. 339, 91 T.C. 339">340 (1988). 2013 Tax Ct. Memo LEXIS 59">*64 The term "deficiency" is defined in section 6211(a) to mean

the amount by which the tax imposed * * * exceeds the excess of—