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respective amounts of $9,707 and $1,755.56.
Petitioners did not file a petition in the Court with
respect to the notice relating to their taxable year 1998.
Instead, on July 20, 2000, in response to the notice, petitioners
sent a letter (petitioners’ July 20, 2000 letter) to the Internal
Revenue Service that contained statements, contentions, argu-
ments, and requests that the Court finds to be frivolous and/or
groundless.3
On May 7, 2001, respondent assessed petitioners’ tax, as
well as any penalties and interest as provided by law, for their
taxable year 1998. (We shall refer to those assessed amounts, as
well as interest as provided by law accrued after May 7, 2001, as
petitioners’ unpaid liability for 1998.)
Respondent issued to petitioners the notice and demand for
payment required by section 6303(a) with respect to petitioners’
unpaid liability for 1998.
On August 23, 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
1998. On or about September 23, 2001, in response to the notice
of intent to levy, petitioners filed Form 12153, Request for a
3Petitioners’ July 20, 2000 letter is very similar to the
letters that certain other taxpayers with cases in the Court sent
to the Internal Revenue Service in response to the notices issued
to them. See, e.g., Copeland v. Commissioner, supra; Smith v.
Commissioner, supra.
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