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(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.
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