specified submission
(2) Specified frivolous submission For purposes of this section— (A) Specified frivolous submission The term “specified frivolous submission” means a specified submission if any portion of such submission— (i) is based on a position which the Secretary has identified as frivolous under subsection (c), or (ii) reflects a desire to delay or impede the administration of Federal tax laws. (B) Specified submission The term “specified submission” means— (i) a request for a hearing under— (I) section 6320 (relating to notice and opportunity for hearing upon filing of notice of lien), or (II) section 6330 (relating to notice and opportunity for hearing before levy), and (ii) an application under— (I) section 6159 (relating to agreements for payment of tax liability in installments), (II) section 7122 (relating to compromises), or (III) section 7811 (relating to taxpayer assistance orders).