- 3 - which was the total amount of Federal income tax withheld. Petitioners also attached a typewritten statement to the Form 1040 reciting contentions and arguments that this Court has found to be frivolous and/or groundless. Respondent determined a deficiency and an accuracy-related penalty in petitioners’ 1997 Federal income tax and issued a notice of deficiency to petitioners on July 21, 2000. Petitioners received the notice of deficiency but did not file a petition for redetermination of a deficiency with this Court for taxable year 1997. Respondent issued to each petitioner a Letter 1058, Final Notice of Intent to Levy and Notice of Your Right to a Hearing, on October 9, 2003, for taxable year 1997. Petitioners sent respondent a letter dated November 5, 2003, requesting a section 6330 hearing. Throughout their correspondence with respondent, petitioners continued to make contentions and arguments that this Court has found to be frivolous and/or groundless. In letters dated July 6 and July 22, 2004, respondent’s settlement officer attempted to schedule an administrative hearing with petitioners. Respondent informed petitioners that a face-to-face hearing would not be available if the only items raised by petitioners are arguments or contentions that courts have determined to be frivolous and/or groundless.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011