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On or about May 9, 2003, in response to the notice of intent
to levy, petitioner filed Form 12153, Request for a Collection
Due Process Hearing (petitioner’s Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office).
Petitioner attached a document to petitioner’s Form 12153 (peti-
tioner’s attachment to Form 12153), in which he claimed that the
notice of deficiency for 1996 and 1997 was “facially void” and
advanced other statements, contentions, and arguments that the
Court finds to be frivolous and/or groundless.
On October 21, 2003, an Appeals Office settlement officer
(settlement officer) sent petitioner a letter (October 21, 2003
letter) acknowledging receipt of petitioner’s Form 12153. That
letter stated in pertinent part:
Based on my review of the case, the assessments which
are currently outstanding for collection (as referenced
on Letter 1058 mentioned above), were TEFRA flow-
through adjustments from two TEFRA entities: Winn
[sic] Enterprises, LC and Stephens City Chiropractic,
PLC.
There are additional PROPOSED assessments, resulting
from affected items from the TEFRA entities. These
proposed assessments were explained in a Notice of
Deficiency which I can see you have petitioned to Tax
Court. However, please do not confuse the two issues.
The amounts addressed on Letter 1058, for the tax years
1996 and 1997, do not include these additional PROPOSED
assessments. Included are only the amounts for which
6(...continued)
1996 and 1997 that the Court sustained in petitioner’s affected
items proceeding. Hudspath v. Commissioner, T.C. Memo. 2004-75.
Consequently, the assessments with respect to those respective
deficiencies are not at issue in the instant case.
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Last modified: May 25, 2011