- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011