- 3 -
1999.)
On April 24, 2000, respondent issued to petitioners a notice
of balance due with respect to petitioners’ respective unpaid
liabilities for 1998 and 1999. On October 8, 2001, respondent
issued to petitioners another notice of balance due with respect
to such unpaid liabilities.
On January 31, 2002, respondent issued to petitioners a
notice of Federal tax lien filing and your right to a hearing
(notice of tax lien) with respect to their taxable years 1998 and
1999.
On or about February 25, 2002, in response to the notice of
tax lien, petitioners mailed Form 12153, Request for a Collection
Due Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). Petitioners
attached a document to their Form 12153 (petitioners’ attachment
to Form 12153) that contained statements, contentions, arguments,
and requests that the Court finds to be frivolous and/or ground-
less.4
By letter dated October 31, 2002 (October 31, 2002 letter),
a settlement officer with respondent’s Appeals Office (settlement
4Petitioners’ attachment to Form 12153 contained statements,
contentions, arguments, and requests that are very similar to the
statements, contentions, arguments, and requests contained in the
attachments to respective Forms 12153 filed with the Internal
Revenue Service by certain other taxpayers who commenced proceed-
ings in the Court. See, e.g., Guerrier v. Commissioner, T.C.
Memo. 2002-3.
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