- 5 - (Appeals Office). 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.5 On February 25, 2002, a settlement officer with the Appeals Office (settlement officer) sent petitioners a letter. That letter stated in pertinent part: Per our recent telephone conversation I have scheduled the Collection Due Process hearing you requested on this case for the time and date shown above [April 5, 2002] * * * Appeals’ jurisdiction to hear your case is specified in the Internal Revenue Code, 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 enclosing the most recent copies of literal tran- scripts of your account for the above years [1997 and 1998] and plan to have updated transcripts for you at the hearing. Your request for additional documents is properly made under the Freedom of Information Act. You will need to send your request to the Disclosure Officer at [the] Internal Revenue Service, 210 E. Earll, Phoenix, Arizona 85012. I have reviewed the correspondence you attached to your request for the collection due process hearing and 5Petitioners’ attachment to Form 12153 contained statements, contentions, arguments, and requests that are similar to the statements, contentions, arguments, and requests contained 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011