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6662(a)2 on, petitioners’ tax for that year in the respective
amounts of $15,447 and $1,921.49.
Petitioners did not file a petition in the Court with
respect to the notice relating to their taxable year 1997.
Instead, on February 12, 2000, in response to the notice, peti-
tioners sent a letter (petitioners’ February 12, 2000 letter) to
the Internal Revenue Service that contained statements, conten-
tions, arguments, and requests that the Court finds to be frivo-
lous and/or groundless.3
On May 8, 2000, respondent assessed petitioners’ tax, as
well as a penalty and interest as provided by law, for their
taxable year 1997. (We shall refer to any such unpaid assessed
amounts, as well as interest as provided by law accrued after May
8, 2000, as petitioners’ unpaid liability for 1997.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid liability for 1997.
On August 17, 2000, respondent issued to petitioners a final
notice of intent to levy and notice of your right to a hearing
2All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
3Petitioners’ February 12, 2000 letter is very similar to
the letters that certain other taxpayers with cases in the Court
sent to the Internal Revenue Service in response to the notices
issued to them. See, e.g., Copeland v. Commissioner, supra;
Smith v. Commissioner, supra.
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