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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.
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