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On April 19, 2005, petitioner sent respondent a Form 12153,
Request for a Collection Due Process Hearing.
Respondent’s Appeals officer reviewed petitioner’s
correspondence and determined that all of petitioner’s
contentions were frivolous. On July 25, 2005, respondent’s
Appeals officer sent petitioner a letter in which respondent
notified petitioner that respondent had received petitioner’s
request for a section 6330 hearing and scheduled a telephone
conference for August 17, 2005, at 3 p.m. The letter advised
petitioner that the underlying liabilities could not be raised at
the hearing because petitioner had received statutory notices of
deficiency.2 Respondent’s letter also directed petitioner to an
Internal Revenue Service (IRS) publication, “The Truth About
Frivolous Tax Arguments”, available on the IRS’s Web site.
Finally, the letter advised petitioner of this Court’s authority
to impose a sanction of up to $25,000 pursuant to section 6673.
Petitioner did not respond to this letter and failed to
participate in the scheduled phone conference. On August 22,
2005, respondent sent petitioner a letter again requesting that
petitioner contact respondent and provide any additional
2Petitioner denies receiving a statutory notice of
deficiency. However, this is only because petitioner claims to
have received “non-statutory” notices of deficiency.
Accordingly, the fact of receipt is deemed conceded.
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Last modified: May 25, 2011