- 3 - shall refer to any such unpaid assessed amounts, as well as interest as provided by law accrued after July 21, 2003, as petitioner’s unpaid liability for 1996.) Respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid liability for 1996. On November 6, 2003, respondent issued to petitioner a notice of Federal tax lien filing and your right to a hearing (notice of tax lien) with respect to his taxable year 1996. On December 9, 2003, in response to the notice of tax lien, petitioner filed a request for a collection due process hearing (petitioner’s request for an Appeals Office hearing) and requested a hearing with respondent’s Appeals Office (Appeals Office).3 Petitioner’s request for an Appeals Office hearing contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.4 By letter dated May 19, 2004, an Appeals officer with respondent’s Appeals Office (Appeals officer) informed petitioner 3Petitioner did not use Form 12153, Request for a Collection Due Process Hearing. 4Petitioner’s request for an Appeals Office hearing contained statements, contentions, arguments, and requests that are similar to the statements, contentions, arguments, and requests contained in the respective Appeals Office hearing requests filed under sec. 6320(b) and/or sec. 6330(b) with the Internal Revenue Service by certain other taxpayers who commenced proceedings in the Court. See, e.g., Guerrier v. Commissioner, T.C. Memo. 2002-3.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011