William A. Hoffman, Jr. - Page 5
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contesting the underlying deficiency in a proceeding in this
Court under section 6330(d).
Petitioner does not dispute that he received a notice of
deficiency and failed to file a timely petition with this Court
pursuant to section 6213 for redetermination of that deficiency.
Petitioner further does not dispute that he failed to raise any
of the issues listed in section 6330(c)(2)(A) at the July 14,
1999, meeting with respondent's Appeals Office. Rather,
petitioner continues to put forth frivolous arguments that have
been universally rejected by this and other courts. Because,
however, petitioner received a notice of deficiency and failed to
file a timely petition with this Court for redetermination of
that deficiency, he is precluded from raising any issue regarding
his underlying tax liability at this time. Consequently, we
sustain respondent's determination in the Notice of Determination
Concerning Collection Actions Under Section 6320 and/or 6330.
Petitioner perhaps did not realize the frivolity of his
petition in the instant case. Accordingly, we warn petitioner
that pursuant to section 6673 we are authorized to impose a
penalty of up to $25,000 on taxpayers who institute proceedings
merely for delay or who set forth in a proceeding a position that
is frivolous or groundless. Petitioner should bear that fact in
mind in connection with any further proceedings which he may
institute in this Court.
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Last modified: May 25, 2011