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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.
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