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ments, contentions, arguments, and requests that the Court finds
to be frivolous and/or groundless.7
On May 14, 2002, the settlement officer held an Appeals
Office hearing with petitioner with respect to the notice of tax
lien and notice of intent to levy. Prior to the Appeals Office
hearing, the settlement officer gave petitioner Form 4340,
Certificate of Assessments, Payments, and Other Specified Matters
(Form 4340), with respect to each of petitioner’s taxable years
1997 and 1998.
On July 30, 2002, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to the notice of determination stated in pertinent part:
Verification of Legal and Procedural Requirements
The Secretary has provided sufficient verification that
the requirements of any applicable law or administra-
tive procedure have been met.
Certified account transcripts, Forms 4340, were re-
quested and reviewed along with the administrative
return files for 1997 and 1998. * * *
* * * * * * *
The collection due process hearing was held on May 14,
7Petitioner’s May 8, 2002 letter contained statements,
contentions, arguments, and requests that are similar to the
types of statements, contentions, arguments, and requests con-
tained 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.
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