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years 1994, 1995, and 1996.)
On or about November 2, 2001, in response to both respon-
dent’s February 5, 1999 notice of intent to levy concerning Ms.
Holguin’s taxable years 1994, 1995, and 1996 and respondent’s
October 4, 2001 notice of intent to levy concerning Mr. Holguin’s
taxable years 1994, 1995, and 1996, petitioners filed jointly
Form 12153, Request for a Collection Due Process Hearing (Form
12153), and requested a hearing with respondent’s Appeals Office
(Appeals Office). Mr. Holguin timely filed that form as to
respondent’s October 4, 2001 notice of intent to levy concerning
Mr. Holguin’s taxable years 1994, 1995, and 1996, but Ms. Holguin
did not timely file that form as to respondent’s February 5, 1999
notice of intent to levy concerning Ms. Holguin’s taxable years
1994, 1995, and 1996. Petitioners attached a document to their
Form 12153 (petitioners’ attachment to Form 12153) that contained
statements, contentions, and arguments, that the Court finds to
be frivolous and/or groundless.10
On April 18, 2002, respondent’s Appeals officer (Appeals
officer) held a hearing that constituted (1) an Appeals Office
hearing with Mr. Holguin with respect to respondent’s October 4,
2001 notice of intent to levy concerning his taxable years 1994,
10Petitioners’ attachment to Form 12153 is 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, T.C. Memo. 2003-46;
Smith v. Commissioner, T.C. Memo. 2003-45.
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