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Notice and Demand for payment must be made on a Form 17. We find
petitioners’ positions to be misguided. Petitioners’ other
arguments at trial were without merit and not worthy of mention.
After reviewing this record and hearing petitioners’
arguments, we conclude and hold that respondent did not abuse his
discretion in determining to proceed with enforced collection
activity.3
Respondent’s Motion for Summary
Judgment will be granted, and a decision
entered permitting respondent to proceed
with collection.
3 We must note that petitioners’ efforts appear to be solely
focused on avoiding payment and/or collection of tax on wages
that they admit receiving. Throughout the lengthy administrative
process and at the hearing on summary judgment petitioners did
not raise anything but frivolous and baseless arguments, most of
which have been rejected on numerous occasions by this and other
courts. We admonish petitioners that we shall consider the
imposition of a penalty under sec. 6673 in any future proceeding
where petitioners raise the same arguments.
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Last modified: May 25, 2011