- 4 - Process Hearing (Form 12153), and requested a hearing with respondent’s Appeals Office (Appeals Office). In that form, petitioners stated that they intended to make an audio recording of their Appeals Office hearing. Petitioners attached a document to their Form 12153 (petitioners’ attachment to Form 12153) that contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.4 On August 7, 2001, August 24, 2001, and September 5, 2001, respectively, respondent applied payments of $1,957.59, $1,884.97, and $1,803.94 to petitioners’ account with respect to their taxable year 1998. On May 15, 2002, respondent’s Appeals officer (Appeals officer) held an Appeals Office hearing with petitioners with respect to the notice of tax lien. At the Appeals Office hear- ing, the Appeals officer gave petitioners Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340), with respect to their taxable year 1998. On June 18, 2002, the Appeals Office issued to petitioners a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination). An attach- 4Petitioners’ attachment to Form 12153 contained statements, contentions, arguments, and requests that are very 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, T.C. Memo. 2003-60.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011