Randy S. Quigley - Page 4

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          unpaid liability for 1999.                                                   
               On or about July 4, 2003, 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 petitioner’s              
          taxable year 1999.  On or about July 25, 2003, 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 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.7                          
               In response to petitioner’s Form 12153 and petitioner’s                 
          attachment to Form 12153, an Appeals officer with the Appeals                
          Office (Appeals officer) sent a letter to petitioner on January              
          5, 2004 (Appeals officer’s January 5, 2004 letter), which stated             
          in pertinent part:                                                           
               Please note that during my preliminary review of your                   
               “Request for a Due Process Hearing” and other documents                 
               written by you, it was observed that you are raising                    
               points that are frivolous and without merit.                            


               7Petitioner’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 respective Forms 12153 filed with the IRS by                  
          certain other taxpayers who commenced proceedings in the Court.              
          See, e.g., Flathers v. Commissioner, T.C. Memo. 2003-60; Copeland            
          v. Commissioner, supra.                                                      





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