-14- indefinitely and did not agree on any date or time for a hearing. Thus, notwithstanding petitioner’s request to have a “hearing” under section 6330, we consider it neither necessary or productive to remand this case to Appeals to hold a hearing. Lunsford v. Commissioner, 117 T.C. 183 (2001). We sustain respondent’s determination as to the proposed levy as a permissible exercise of discretion. We find petitioner’s arguments to be frivolous and/or groundless. We admonish petitioner, if he appears in this Court again, not to make the same type of arguments. Should petitioner decide to disregard our warning and to continue advancing frivolous and/or groundless arguments, we shall consider imposing a penalty on petitioner under section 6673(a). We have considered all arguments and have found those arguments not discussed herein to be irrelevant and/or without merit. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011