Hugh D. Summers and Teresa E. Summers - Page 10

                                       - 10 -                                         
          the Form 12153 was a 37-page letter consisting of nothing but               
          frivolous tax protester boilerplate.                                        
               Because petitioners’ cases were still pending in District              
          Court, respondent did not immediately schedule a section 6330               
          hearing.  On March 14, 2005, approximately 2 months after the               
          Third Circuit Court of Appeals affirmed the District Court’s                
          judgments in favor of respondent, respondent’s Appeals Office               
          sent petitioners a letter advising them that the Appeals Office             
          would schedule an appointment.  In a letter dated March 23, 2005,           
          Mr. Summers advised respondent’s Appeals Office that his appeal             
          process would not be complete until there was a final                       
          determination by the District Court and requested that                      
          respondent’s Appeals Office hold the matter in abeyance until               
          such a determination had been made.                                         
               On April 8, 2005, respondent’s Settlement Officer Edith M.             
          Dermody (Ms. Dermody), wrote petitioners and advised them that              
          the arguments raised in their section 6330 hearing request were             
          frivolous, that respondent would not schedule a face-to-face                
          conference if petitioners wished to discuss only frivolous                  
          arguments, and that a telephone conference was scheduled for                
          April 28, 2005.  On April 21, 2005, Mr. Summers sent Ms. Dermody            
          a letter requesting a copy of their Form 12153,5 requesting a               

               5In his Apr. 21, 2005, letter, Mr. Summers stated that he              
          did not recall making a request for a sec. 6330 hearing and that            
                                                             (continued...)           





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