- 4 -
Type Period Assessed Statutory
of Tax Ending Balance Additions Total
1040A 12-31-1995 $462.53 $105.63 $568.16
1040 12-31-1999 3,946.11 234.32 4,180.43
On or about September 28, 2000, 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).
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.2
On February 28, 2001, respondent’s Appeals officer (Appeals
officer) held an Appeals Office hearing with petitioner with
respect to the notice of intent to levy. On May 8, 2001, the
Appeals officer held a second Appeals Office hearing (May 8, 2001
hearing) with petitioner with respect to the notice of intent to
levy. At the May 8, 2001 hearing, petitioner provided the
Appeals officer with a copy of Form 1040X, Amended U.S. Individ-
ual Income Tax Return, for his taxable year 1999 (amended 1999
return). In his amended 1999 return, petitioner reported total
2Petitioner’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., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v.
Commissioner, T.C. Memo. 2003-45.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011