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Collection Due Process Hearing (Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office).
Petitioner attached a document to her Form 12153 (petitioner’s
attachment to Form 12153) that contained statements, contentions,
arguments, and requests that the Court finds to be frivolous
and/or groundless.5
On January 31, 2001, respondent’s Appeals officer held an
Appeals Office hearing with petitioner with respect to the notice
of intent to levy. At the Appeals Office hearing, the Appeals
officer gave petitioner a summary record of assessments with
respect to her taxable year 1996.
On February 6, 2001, the Appeals Office issued to petitioner
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:
Applicable Law and Administrative Procedures
Based on the information available, the requirements of
applicable law and administrative procedures have been
met.
Internal Revenue Code Section 6331(d) requires that the
Internal Revenue Service notify a taxpayer at least 30
days before a Notice of Levy can be issued. The 30-day
notice was mailed to you at the last known address via
5Petitioner’s 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., Fink v. Commissioner, T.C. Memo. 2003-61.
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Last modified: May 25, 2011