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penalty should be imposed against petitioner. Respondent alleges
that all section 6330 prerequisites have been met and that he
should be allowed to proceed with collection of petitioner’s
assessed and outstanding tax liability. With respect to the
penalty, respondent contends that petitioner instituted this
proceeding primarily for delay and that his position in the
proceeding is frivolous and groundless.
Petitioner’s objection to respondent’s motion for summary
judgment was filed on December 23, 2002. In essence, petitioner
contends that, although respondent has sent certain documents to
him, those documents are not acceptable because they do not meet
the standards that petitioner contends exist. In particular,
petitioner contends that the Secretary of the Treasury must
personally sign notices or that respondent must prove that the
person who did sign notices sent to him was properly authorized
to sign. Petitioner also contends that he will not treat
decisions of the Tax Court as law by which he is bound unless it
is shown that “the Congress of the United States passed a law
stating that the U.S. Citizen is bound by Tax Court decisions.”
Background
Petitioner resided in Moreno Valley, California, at the time
his petition was filed. Petitioner’s 1995 Federal income tax
return was filed on April 15, 1996, and reflected $46,294 in
taxable income and an $11,767 income tax liability. The tax
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