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On September 11, 2000, respondent issued to petitioners a
notice of balance due with respect to petitioners’ unpaid liabil-
ity for 1999.
On or about September 20, October 25, and November 29, 2000,
and January 28 and March 27, 2001, petitioners sent respondent
payments totaling $2,457 with respect to petitioners’ unpaid
liability for 1999. Petitioners did not make any payments after
March 27, 2001, with respect to that unpaid liability.
On November 8, 2001, respondent issued to petitioners a
final notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to their taxable
year 1999. On December 4, 2001, in response to the notice of
intent to levy, petitioners filed Form 12153, Request for a
Collection Due Process Hearing (Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office).
Petitioners attached, inter alia, a document to their Form 12153
(petitioners’ attachment to Form 12153) that contained state-
ments, contentions, arguments, and requests that the Court finds
to be frivolous and/or groundless.3
On August 28, 2002, a settlement officer with respondent’s
3Petitioners’ attachment to Form 12153 contained statements,
contentions, arguments, and requests that are similar to the
statements, contentions, arguments, and requests contained in the
attachment to Form 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. Commis-
sioner, T.C. Memo. 2003-45.
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