Daniel E. Duncan - Page 5




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          of Federal tax lien filing and your right to a hearing (notice of           
          tax lien) with respect to his taxable years 1997 and 1998.  On or           
          about April 21, 2001, in response to the notice of tax lien,                
          petitioner filed Form 12153, Request for a Collection Due Process           
          Hearing (Form 12153 regarding notice of tax lien), and requested            
          a hearing with respondent’s Appeals Office (Appeals Office).                
          Petitioner attached, inter alia, several documents to Form 12153            
          regarding his notice of tax lien (petitioner’s attachments to               
          Form 12153 regarding notice of tax lien) that contained state-              
          ments, contentions, arguments, and requests that the Court finds            
          to be frivolous and/or groundless.5                                         
               On June 23, 2001, respondent issued to petitioner a final              
          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to his taxable years 1997           
          and 1998.  On July 6, 2001, in response to the notice of intent             
          to levy, petitioner filed Form 12153, Request for a Collection              
          Due Process Hearing (Form 12153 regarding notice of intent to               
          levy), and requested a hearing with the Appeals Office.  Peti-              
          tioner attached, inter alia, several documents to Form 12153                



               5Petitioner’s attachments to Form 12153 regarding notice of            
          tax lien contained statements, contentions, arguments, and                  
          requests that are similar to the statements, contentions, argu-             
          ments, and requests contained in the attachments to Forms 12153             
          filed with the Internal Revenue Service by certain other taxpay-            
          ers with cases in the Court.  See, e.g., Copeland v. Commis-                
          sioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C. Memo.               
          2003-45.                                                                    





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