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to each of those amended returns (collectively, petitioner’s
attachments to his amended returns for 1994, 1995, and 1996) that
contained statements, contentions, arguments, and requests that
the Court finds to be frivolous and/or groundless.2
On or about May 10, 2000, 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 respondent’s
assessed amounts for petitioner’s taxable year 1994 and peti-
tioner’s unpaid liability for 1995. On or about the same date,
respondent issued to petitioner a separate notice of intent to
levy with respect to petitioner’s unpaid liability for 1996.
On May 14, 2000, in response to the notices of intent to
levy, petitioner filed Form 12153, Request for a Collection Due
Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). Petitioner at-
tached a document to Form 12153 (petitioner’s attachment to Form
12153) that contained statements, contentions, arguments, and
requests that the Court finds to be frivolous and/or groundless.3
2Petitioner’s attachments to his amended returns for 1994,
1995, and 1996 contained statements, contentions, arguments, and
requests that are very similar to the statements, contentions,
arguments, and requests contained in the attachments to Forms
1040 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.
3Petitioner’s attachment to Form 12153 contained statements,
(continued...)
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