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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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