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Tax Lien Filing and Notice of Your Right to a Hearing. The
notice advised petitioner he was entitled to request a hearing to
appeal the collection action and to discuss optional payment
methods. On January 27, 2003, petitioner submitted Form 12153,
Request for a Collection Due Process Hearing. In his request, he
again raised frivolous arguments.
On July 10, 2003, respondent’s Appeals Office mailed
petitioner a letter acknowledging receipt of his case for
consideration and notifying him that he must file Federal income
tax returns for 2000, 2001, and 2002 if he wished to have
alternative collection measures considered.2 In response, by
letter dated July 31, 2003, petitioner stated that he is not
required to file tax returns in order to receive a hearing and
asserted other frivolous arguments. By letter dated July 31,
2003, petitioner requested a face-to-face conference. On
September 30, 2003, Settlement Officer Spencer Dolin mailed a
letter to petitioner, which stated, in part, that Appeals does
not provide a face-to-face conference if the only items to
discuss are frivolous or groundless arguments and “if you are
interested in receiving a face-to-face conference, you must be
2 Additionally, by letters dated Sept. 30 and Oct. 15, 2003,
Settlement Officer Spencer Dolin again advised petitioner that
all income tax returns must be filed if petitioner wished to have
alternative collection measures considered.
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Last modified: May 25, 2011