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Type Period Assessed Statutory
of Tax Ending Balance Additions Total
1040A 12-31-1987 $7,777.54 $5,939.64 $13,717.18
1040A 12-31-1988 7,200.48 5,518.33 12,718.81
1040A 12-31-1989 6,324.24 4,924.69 11,248.93
1040A 12-31-1993 3,239.00 846.03 4,085.03
1040A 12-31-1994 7,790.00 2,079.30 9,869.30
1040A 12-31-1995 2,374.00 659.66 3,033.66
Civ. pen. 12-31-1995 500.00 30.92 530.92
Civ. pen. 12-31-1996 500.00 30.92 530.92
In response to the notice of intent to levy, petitioner
submitted more than one Form 12153, Request for a Collection Due
Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office).3 Petitioner at-
tached a document to each of his Forms 12153 (collectively,
petitioner’s attachments to Forms 12153) that contained state-
ments, contentions, arguments, and requests that the Court finds
to be frivolous and/or groundless.4
3Petitioner submitted three Forms 12153. On Dec. 29, 1999,
petitioner submitted Form 12153 with respect to his taxable years
1987, 1988, 1989, 1993, 1994, 1995, and 1996. On Mar. 2, 2000,
the Appeals Office returned that form because it lacked an
original signature. On Mar. 21, 2000, respondent received a
second Form 12153, with petitioner’s original signature, with
respect to his taxable years 1987, 1988, 1989, 1993, 1994, 1995,
and 1996. On June 12, 2000, petitioner sent a letter to the
Internal Revenue Service and attached to that letter, inter alia,
a third Form 12153 with respect to his taxable years 1994 and
1996.
4Petitioner’s attachments to Forms 12153 contained state-
ments, contentions, arguments, and requests that are similar to
the statements, contentions, arguments, and requests contained in
the attachment to Forms 12153 filed with the Internal Revenue
Service by certain other taxpayers with cases in the Court. See,
(continued...)
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Last modified: May 25, 2011