Ronald Lee Snyder - Page 6

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          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to his taxable years                
          1991, 1994, 1996, 1998, and 1999.  On May 31, 2002, respondent              
          issued to petitioner a notice of Federal tax lien filing and your           
          right to a hearing (notice of tax lien) with respect to those               
          same taxable years.                                                         
               On or about June 27, 2002, in response to the notice of                
          intent to levy and the notice of tax lien, petitioner mailed Form           
          12153, Request for a Collection Due Process Hearing (Form 12153),           
          and requested a hearing with respondent’s Appeals Office (Appeals           
          Office).  The Internal Revenue Service (IRS) received that form             
          on July 1, 2002.  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                                   
               The Appeals Office determined that petitioner’s Form 12153             
          was timely filed with respect to the notice of tax lien but was             
          not timely filed with respect to the notice of intent to levy.6             


               5Petitioner’s 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 IRS by                 
          certain other taxpayers who commenced proceedings in the Court.             
          See, e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v.           
          Commissioner, T.C. Memo. 2003-45.                                           

               6As discussed below, respondent now acknowledges that peti-            
                                                             (continued...)           




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