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his taxable years 1996 and 1997.)
On May 24, 1999, respondent issued to petitioner a notice of
balance due with respect to petitioner’s unpaid liability for
each of his taxable years 1996 and 1997. On June 28, 1999,
respondent issued a second notice of balance due with respect to
each such unpaid liability.
On April 7, 2000, respondent filed a Federal tax lien with
respect to petitioner’s unpaid liability for each of his taxable
years 1996 and 1997.
On April 13, 2000, respondent issued to petitioner a notice
of Federal tax lien filing and your right to a hearing (notice of
lien) with respect to petitioner’s unpaid liability for each of
his taxable years 1996 and 1997.5 On or about May 12, 2000, in
response to the notice of lien, petitioner filed Form 12153,
Request for a Collection Due Process Hearing (Form 12153), and
requested a hearing with respondent’s Appeals Office (Appeals
Office). Petitioner attached a document to his Form 12153
(petitioner’s attachment to Form 12153) that contained state-
ments, contentions, arguments, and requests that the Court finds
to be frivolous and/or groundless.6
5The notice of lien also pertained to a frivolous return
penalty under sec. 6702 regarding each of petitioner’s returns
for 1996 and 1997.
6Petitioner’s attachment to Form 12153 contained statements,
contentions, arguments, and requests that are similar to the
(continued...)
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