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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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Last modified: May 25, 2011