Nicholas & Carrie Cozzens - Page 3

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          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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