- 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011