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regarding notice of intent to levy (petitioner’s attachments to
Form 12153 regarding notice of levy) that contained statements,
contentions, arguments, and requests that the Court finds to be
frivolous and/or groundless.6
On April 10, 2002, a settlement officer with the Appeals
Office (settlement officer) sent petitioner a letter (settlement
officer’s April 10, 2002 letter). That letter stated in perti-
nent part:
I have scheduled the Collection Due Process hearing you
requested on this case for the time and date shown
above [May 14, 2002]. * * *
* * * * * * *
Appeals’ jurisdiction to hear your case is specified in
the Internal Revenue code [sic], Sections 6320 and
6330, and the related federal regulations. Appeals
will consider the appropriateness of the proposed
collection action, spousal defenses, and collection
alternatives. If you received a statutory notice of
deficiency * * * you may not raise as an issue the
amount or existence of the underlying assessment. * * *
I am also enclosing Forms 2866, Certificate of Official
Record, and Forms 4340, Certificate of Assessment for
the Forms 1040EZ for the 1997 and 1998 tax years,
* * *. These documents meet the verification require-
ments under IRC �6330(c)(1). Your request for addi-
tional information should be made under the Freedom of
Information Act through the Disclosure Officer located
at the Internal Revenue Service, 210 E. Earll, Phoenix,
Arizona 85012.
6Petitioner’s attachments to Form 12153 regarding notice of
intent to levy are similar to the types of 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, supra; Smith v. Commissioner, supra.
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