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Petitioner did not file a petition in the Court with respect
to the notice relating to her taxable year 1996. Instead, on
March 5, 1999, in response to the notice, petitioner sent a
letter (petitioner’s March 5, 1999 letter) to the Internal
Revenue Service that contained statements, contentions, argu-
ments, and requests that the Court finds to be frivolous and/or
groundless.4
On September 13, 1999, respondent assessed petitioner’s tax,
as well as an addition to tax, a penalty, and interest as pro-
vided by law, for her taxable year 1996. (We shall refer to
those assessed amounts, as well as interest as provided by law
accrued after September 13, 1999, as petitioner’s unpaid liabil-
ity for 1996.)
On September 13, October 18, and December 27, 1999, respon-
dent issued to petitioner separate notices of balance due with
respect to petitioner’s unpaid liability for 1996.
On August 19, 2000, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to her taxable year 1996.
On or about September 15, 2000, in response to the notice of
intent to levy, petitioner filed Form 12153, Request for a
4Petitioner’s March 5, 1999 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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