Michael Balice - Page 3

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          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.                                                          




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