- 5 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011