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return penalty under section 6702 with respect to his taxable
year 1998.
On or about April 7, 2000, in response to the notice of
intent to levy, petitioner filed Form 12153, Request for a
Collection Due Process Hearing (petitioner’s Form 12153), and
requested a hearing with respondent’s Appeals Office (Appeals
Office).5 Petitioner’s Form 12153 contained statements, conten-
tions, arguments, and/or requests that the Court finds to be
frivolous and/or groundless.6
On or about August 17, 2000, petitioner sent a letter
(petitioner’s August 17, 2000 letter) to a settlement officer
with respondent’s Appeals Office (settlement officer) in which
petitioner requested certain documents. That letter contained
requests that the Court finds to be frivolous and/or groundless.7
5The notice of intent to levy did not pertain to peti-
tioner’s taxable year 1996. Nonetheless, petitioner indicated in
petitioner’s Form 12153 that he was requesting a hearing with
respondent’s Appeals Office with respect to that year as well as
his taxable years 1992, 1993, 1994, and 1998.
6Petitioner’s Form 12153 contained statements, contentions,
arguments, and/or requests that are similar to the statements,
contentions, arguments, and/or requests contained in the attach-
ments to Forms 12153 filed with the IRS by certain other taxpay-
ers with cases in the Court. See, e.g., Copeland v. Commis-
sioner, supra; Smith v. Commissioner, supra.
7Petitioner’s August 17, 2000 letter contained requests that
are similar to the requests that certain other taxpayers with
cases in the Court made to the IRS. See, e.g., Copeland v.
Commissioner, supra; Smith v. Commissioner, supra.
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