- 4 - another notice of balance due with respect to that unpaid liabil- ity. On November 5, 2002, respondent issued to petitioner a final notice of intent to levy and notice of your right to a hearing (notice of intent to levy) with respect to, inter alia, his taxable year 1999. On or about December 2, 2002, in response to the notice of intent to levy, petitioner filed Form 12153, Request for a Collection Due Process Hearing (Form 12153), and requested a hearing with respondent’s Appeals Office (Appeals Office) with respect to, inter alia, his taxable year 1999. Petitioner attached a document to his Form 12153 (petitioner’s attachment to Form 12153) that contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.5 On September 8, 2003, a settlement officer with respondent’s Appeals Office held a hearing (Appeals Office hearing) with petitioner with respect to the notice of intent to levy. At the Appeals Office hearing, the settlement officer gave petitioner a copy of Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340), with respect to petitioner’s 5Petitioner’s attachment to Form 12153 contained statements, contentions, arguments, and requests that are similar to the statements, contentions, arguments, and requests contained in the attachments to Forms 12153 filed with the Internal Revenue Service by certain other taxpayers with cases in the Court. See, e.g., Flathers v. Commissioner, supra; Copeland v. Commissioner, supra.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011