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The taxpayer raised no non-frivolous issues. The
information previously submitted by the taxpayers was
reviewed, and in that material Karen Kemper raised no
non-filer issues.
Balancing the Need for Efficient Collection with Tax-
payer Concerns
The requirements of all applicable laws and administra-
tive procedures have been met. The taxpayers received
their required notices. At the hearing, Appeals raised
collection alternatives with George Kemper, but he was
not interested. Given the taxpayers’ continued non-
compliance, the government should be allowed to proceed
with its proposed enforcement action, its intent to
levy on tax periods 1995, 1996, 1997 and 1998. Lacking
the taxpayers’ cooperation, the proposed collection
action balances the need for efficient collection with
the taxpayer’s concern that any collection action be no
more intrusive than necessary. [Reproduced literally]
On October 29, 2002, petitioners filed a petition with the
Court for review of petitioners’ notices of determination only
insofar as those notices relate to petitioners’ unpaid liabili-
ties for 1995, 1996, 1997, and 1998. Except for an argument
under section 7521(a)(1), the petition contains statements,
contentions, arguments, and questions that the Court finds to be
frivolous and/or groundless.7 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 August 29, 2002, and that that
7The frivolous and/or groundless statements, contentions,
arguments, and questions in petitioners’ petition are very
similar to the frivolous and/or groundless statements, conten-
tions, arguments, and questions in petitions filed by certain
other taxpayers with cases in the Court. See, e.g., Keown v.
Commissioner, T.C. Memo. 2003-69.
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Last modified: May 25, 2011