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Collection Due Process Hearing (Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office).
Petitioners attached a document to their Form 12153 (petitioners’
attachment to Form 12153) that contained statements, contentions,
arguments, and requests that the Court finds to be frivolous
and/or groundless.4
On March 12, 2002, a settlement officer with the Appeals
Office (settlement officer) held an Appeals Office hearing with
petitioners with respect to the notice of intent to levy. At the
Appeals Office hearing, the settlement officer gave petitioners a
literal transcript of account (so-called MFTRAX) with respect to
their taxable year 1998.
On April 17, 2002, the Appeals Office issued to petitioners
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to the notice of determination stated in pertinent part:
Verification of Legal and Procedural Requirements
The Secretary has provided sufficient verification that
all legal and procedural requirements have been met.
Computer transcripts have been reviewed by Appeals,
verifying the assessments.
4Petitioners’ attachment to Form 12153 contained statements,
contentions, arguments, and requests that are very 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, supra; Smith v. Commissioner,
supra.
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Last modified: May 25, 2011