- 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.
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Last modified: May 25, 2011