- 4 - statement setting forth frivolous arguments; e.g., “There is no statute requiring me ‘to pay’ the income taxes at issue.”3 Settlement Officer Thomas L. Tracy (Mr. Tracy), of the IRS Office of Appeals in Phoenix, Arizona, sent petitioner a letter dated November 19, 2002, scheduling a hearing for December 10, 2002. The letter briefly outlined the hearing process, advised that audio or stenographic recording of hearings was not allowed, and explained the circumstances in which challenges to the underlying liability would be barred by section 6330(c)(2)(B). The letter also warned petitioner with respect to frivolous arguments and sanctions therefor, citing pertinent cases and administrative materials. Mr. Tracy enclosed with the letter copies of, among other things, transcripts of petitioner’s accounts, financial forms for petitioner’s completion, and Pierson v. Commissioner, 115 T.C. 576 (2000) (discussing the potential application of penalties where tax protesters persist in bringing frivolous cases to this Court). The hearing was subsequently rescheduled for January 7, 2003, and a face-to-face conference between petitioner and Mr. Tracy was held on that date. Following the hearing, respondent on January 23, 2003, issued to petitioner the aforementioned Notice of Determination Concerning Collection Action(s) Under Section 3 See supra note 2.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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