- 6 -
The requirements for all applicable laws and adminis-
trative procedures have been met. The courts have
addressed the arguments presented. You received all
required notices. You were given the opportunity at
the hearing to arrange for payment of the liability but
neglected to do so. You have neglected or refused to
pay. The government should be allowed to proceed with
its proposed enforcement action, the lien. Lacking
your cooperation, the proposed collection action bal-
ances the need for efficient collection with your
concern that any collection action be no more intrusive
than necessary.
On July 22, 2002, petitioners filed a petition with the
Court for review of respondent’s notice of determination with
respect to petitioners’ unpaid liability for 1998. Except for an
argument under section 7521(a)(1), the petition contains state-
ments, contentions, arguments, and requests that the Court finds
to be frivolous and/or groundless.5 With respect to section
7521(a)(1), petitioners allege in the petition that the Appeals
Office refused to allow them to make an audio recording of the
Appeals Office hearing held on May 15, 2002, and that that
refusal was improper under that section.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
5The frivolous and/or groundless statements, contentions,
arguments, and requests in petitioners’ petition are very similar
to the frivolous and/or groundless statements, contentions,
arguments, and requests in petitions filed by certain other
taxpayers with cases in the Court. See, e.g., Copeland v.
Commissioner, T.C. Memo. 2003-46; Smith v. Commissioner, T.C.
Memo. 2003-45.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011