This Frivolous Return Penalty Protest letter was post to my Tips & Tricks for Court group. Since it is one of the best I have ever seen, I thought it warranted being posted here. An .rtf formatted version of this is posted to my Tips & Tricks for Court group.
This is a sample frivolous letter [...]

Internal Revenue Manual 8.22.2.2.12.2 (10-30-2007)
Section 6702 Frivolous Return Penalties and Questionable W-4 Penalties
1. Frivolous Return Penalties and questionable W-4 penalties do not receive a notice that gives the taxpayer an opportunity to go to Appeals. Therefore, issues involving these penalties may be raised in CDP.
2. A taxpayer may challenge the assessment of the [...]