Willie R. Davidson - Page 12




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          a petition for redetermination with this Court.  See sec.                   
          6213(a).  It follows that section 6330(c)(2)(B) generally bars              
          petitioner from challenging the existence or amount of his                  
          underlying tax liability in this collection review proceeding.              
               Even if petitioner were permitted to challenge the validity            
          of the notice of deficiency, petitioner’s argument that the                 
          notice is invalid because respondent’s Service Center director is           
          not properly authorized to issue notices of deficiency is                   
          frivolous and groundless.  See Nestor v. Commissioner, 118 T.C.             
          162, 165 (2002); Goza v. Commissioner, supra.  Further, as the              
          Court of Appeals for the Fifth Circuit has remarked: "We perceive           
          no need to refute these arguments with somber reasoning and                 
          copious citation of precedent; to do so might suggest that these            
          arguments have some colorable merit."  Crain v. Commissioner, 737           
          F.2d 1417, 1417 (5th Cir. 1984).  Suffice it to say that                    
          petitioner is a taxpayer subject to the Federal income tax, see             
          secs. 1(a)(1), 7701(a)(1), (14), and that compensation for labor            
          or services rendered constitutes income subject to the Federal              
          income tax, sec. 61(a)(1); United States v. Romero, 640 F.2d                
          1014, 1016 (9th Cir. 1981).                                                 
               We likewise reject petitioner’s argument that the Appeals              
          officers failed to obtain verification from the Secretary that              
          the requirements of all applicable laws and administrative                  
          procedures were met as required by section 6330(c)(1).  The                 






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