- 4 -
another notice of balance due with respect to that unpaid liabil-
ity.
On November 5, 2002, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to, inter alia, his
taxable year 1999. On or about December 2, 2002, in response to
the notice of intent to levy, petitioner filed Form 12153,
Request for a Collection Due Process Hearing (Form 12153), and
requested a hearing with respondent’s Appeals Office (Appeals
Office) with respect to, inter alia, his taxable year 1999.
Petitioner attached a document to his Form 12153 (petitioner’s
attachment to Form 12153) that contained statements, contentions,
arguments, and requests that the Court finds to be frivolous
and/or groundless.5
On September 8, 2003, a settlement officer with respondent’s
Appeals Office held a hearing (Appeals Office hearing) with
petitioner with respect to the notice of intent to levy. At the
Appeals Office hearing, the settlement officer gave petitioner a
copy of Form 4340, Certificate of Assessments, Payments, and
Other Specified Matters (Form 4340), with respect to petitioner’s
5Petitioner’s attachment to Form 12153 contained statements,
contentions, arguments, and requests that are similar to the
statements, contentions, arguments, and requests contained in the
attachments to Forms 12153 filed with the Internal Revenue
Service by certain other taxpayers with cases in the Court. See,
e.g., Flathers v. Commissioner, supra; Copeland v. Commissioner,
supra.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011