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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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