Richard Rewerts - Page 7

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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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