Emil P. Tolotti, Jr. - Page 11

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               In addition to the bar imposed by section 6330(c)(2)(B),               
          petitioner’s arguments that he is not liable for Federal income             
          tax and that he did not receive amounts taxable as income during            
          1995 are frivolous and groundless.  Goza v. Commissioner, supra.            
          Petitioner asserts that respondent failed to identify the                   
          statutory provisions: (1) Making petitioner liable for Federal              
          income tax; (2) authorizing respondent’s agents to enforce the              
          Internal Revenue Code; and (3) permitting respondent to file a              
          Notice of Federal Tax Lien.  Petitioner also maintains that                 
          respondent erroneously determined that petitioner earned “foreign           
          source” income during 1995 and respondent failed to identify the            
          specific source of such income.  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).                                                            
               Petitioner next asserts that respondent cannot proceed with            
          collection on the ground that the Notice of Federal Tax Lien                
          filed with the Washoe County Recorder in Reno, Nevada, was not              
          certified as required under Nev. Rev. Stat. Ann. sec. 108.829               
          (Michie 2001).4  We note that the Notice of Federal Tax Lien in             

               4  Nev. Rev. Stat. Ann. sec. 108.829 (Michie 2001) provides            
          in pertinent part:                                                          

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