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petitioner’s arguments are without merit. See, e.g., Roberts v.
Commissioner, 118 T.C. 365, 371 (2002); Nestor v. Commissioner,
supra at 167 (as to the argument that assessments are improper
because the tax return reported zero taxable income); Davis v.
Commissioner, 115 T.C. 35, 41 (2000) (as to the argument that a
Form 23C is necessary and that a Form 4340 does not suffice to
verify respondent’s assessments); Dashiell v. Commissioner, T.C.
Memo. 2004-210 (as to petitioner’s claim that no Internal Revenue
Code section makes him liable). We reject these boilerplate tax-
protester arguments as frivolous and without merit.
Petitioner was asked on several occasions in his section
6330 hearing whether he wished to propose any collection
alternatives. Petitioner refused the opportunity. Rather, in
the section 6330 hearing, petitioner continued to assert a
“hodgepodge of unsupported assertions, irrelevant platitudes, and
legalistic gibberish” similar to those previously rejected by the
Court. Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir.
1984); Dunham v. Commissioner, T.C. Memo. 2003-260. Although
petitioner subsequently submitted an offer in compromise to
respondent, it was rejected by respondent’s Offer in Compromise
Group. Petitioner has not presented any evidence or persuasive
arguments to convince us that respondent abused his discretion.
As a result, we hold the issuance of the notice of determination
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