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which was the total amount of Federal income tax withheld.
Petitioners also attached a typewritten statement to the Form
1040 reciting contentions and arguments that this Court has found
to be frivolous and/or groundless.
Respondent determined a deficiency and an accuracy-related
penalty in petitioners’ 1997 Federal income tax and issued a
notice of deficiency to petitioners on July 21, 2000.
Petitioners received the notice of deficiency but did not file a
petition for redetermination of a deficiency with this Court for
taxable year 1997.
Respondent issued to each petitioner a Letter 1058, Final
Notice of Intent to Levy and Notice of Your Right to a Hearing,
on October 9, 2003, for taxable year 1997. Petitioners sent
respondent a letter dated November 5, 2003, requesting a section
6330 hearing. Throughout their correspondence with respondent,
petitioners continued to make contentions and arguments that this
Court has found to be frivolous and/or groundless.
In letters dated July 6 and July 22, 2004, respondent’s
settlement officer attempted to schedule an administrative
hearing with petitioners. Respondent informed petitioners that a
face-to-face hearing would not be available if the only items
raised by petitioners are arguments or contentions that courts
have determined to be frivolous and/or groundless.
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Last modified: May 25, 2011