- 3 - and 1994. Instead, on or about June 5, 1999, in response to the notice, petitioner sent a letter (petitioner’s June 5, 1999 letter) to the Internal Revenue Service (IRS) that contained statements, contentions, arguments, and/or requests that the Court finds to be frivolous and/or groundless.4 On July 19, 1999, respondent assessed petitioner’s tax, as well as an addition to tax and interest as provided by law, for each of his taxable years 1992, 1993, and 1994. (We shall refer to those unpaid assessed amounts, as well as interest as provided by law accrued after July 19, 1999, as petitioner’s unpaid liabilities for 1992, 1993, and 1994.) On July 19, 1999, respondent issued to petitioner a notice of balance due with respect to petitioner’s unpaid liabilities for 1992, 1993, and 1994, as required by section 6303. On August 23, 1999, respondent issued a second notice of balance due with respect to those unpaid liabilities. On March 23, 2000, 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 (1) petitioner’s unpaid liabilities for 1992, 1993, and 1994 and (2) a frivolous 4Petitioner’s June 5, 1999 letter is very similar to the letters that certain other taxpayers with cases in the Court sent to the IRS in response to the notices issued to them. See, e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commis- sioner, T.C. Memo. 2003-45.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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