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a petition for redetermination with this Court. See sec.
6213(a). Under the circumstances, section 6330(c)(2)(B) bars
petitioners from challenging the existence or the amount of their
underlying tax liabilities for the years 1993 through 1997 in
this collection review proceeding.
In addition to the bar imposed by section 6330(c)(2)(B),
petitioners’ arguments that they are not subject to the Federal
income tax are frivolous and groundless. See Nestor v.
Commissioner, 118 T.C. 162, 165 (2002); Goza v. Commissioner,
supra. 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 (5th Cir. 1984). Suffice it
to say that petitioners are taxpayers who are subject to the
Federal income tax on their wages and other sources of income.
See secs. 1(a), (d); 61(a)(1), (3), (4), (7), (11); 72; 85;
408(d); 7701(a)(1), (14).
Petitioners next argue that the Appeals officer 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). We reject petitioners’ argument
because the record establishes that the Appeals officer obtained
and reviewed transcripts of account (Forms 4340) for petitioners’
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