Virgil and Joyce Brashear - Page 4

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          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.                         





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