Laura A. Gavigan - Page 4

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               On August 22, 2001, respondent issued to petitioner a notice           
          of deficiency for 1996.  Petitioner did not file a petition for             
          judicial review with this Court.3                                           
               On July 12, 2002, respondent issued to petitioner a Final              
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing (final notice).  On August 6, 2002, petitioner responded            
          to the final notice by filing a Form 12153, Request for a                   
          Collection Due Process Hearing.                                             
               Petitioner attached a nine-page memorandum to the Form                 
          12153, in which she sets forth frivolous and groundless arguments           
          regarding the Federal income tax system:  E.g., “it is my                   
          contention that no law authorizes the Secretary (let alone any              
          IRS agent) to determine that I owe more in income taxes than the            
          ‘zero’ I reported on any income tax return”; “In addition, * * *            
          I am not disputing the ‘amount’ of the alleged tax ‘liability’,             
          but the very ‘existence’ of an income tax ‘liability’ as a matter           
          of law”.4  Petitioner also requested that respondent produce                

               3  Petitioner wrote letters to several officials of the                
          Internal Revenue Service and the Department of Treasury, claiming           
          that the Government was engaged in an “illegal enforcement                  
          action” because income taxes were “totally voluntary, and not               
          mandatory” and that her notice of deficiency was invalid because            
          it was not sent directly by the Secretary of the Treasury.                  
               4  Petitioner’s shop-worn and universally rejected frivolous           
          arguments regarding the legitimacy of the Federal income tax                
          system warrant no further comment.  See Crain v. Commissioner,              
          737 F.2d 1417, 1417 (5th Cir. 1984) (“We perceive no need to                
          refute these arguments with somber reasoning and copious citation           
                                                             (continued...)           





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