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courts have continuously rejected, that there is no
reason for remanding your case to appeals to hold a
face to face hearing and waste your time, Appeals’
time, and the taxpayers’ money to simply allow you to
document on a tape all of your frivolous arguments.
So the question is as I noted in the * * *
[order], do you have any issues which I have authority
to consider, and which Appeals had authority to
consider at your hearing which you want to raise, and
presumably would have raised at the hearing had you
been given a chance to have the hearing.
An that’s why I denied the government’s motion,
because they did deny you your rights, and we don’t
know whether--I don’t know whether you have any
legitimate issue to raise or not. So that is what you
have to address here.
Petitioner responded with: “Well, my position is that the
hearing was denied, and that I was not able to bring up the
issues that I outlined in a letter when requesting my letter for
certain documents, and et cetera, to be available, and for the
government to have at the hearing. Those were issues that I
wanted to discuss with them.” The Court again reiterated that
such contentions had been ruled meritless, and warned petitioner:
“Making those arguments, and continuing to make those arguments,
and costing the taxpayers a lot of money for me to deal with
them, may result in the application of additional penalties under
Section 6673.” Petitioner’s remaining comments failed to
identify any specific colorable issues for remand and consisted
principally of vague recitations or paraphrases of the statutory
language.
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Last modified: May 25, 2011