- 7 - 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 determinationPage: Previous 1 2 3 4 5 6 7 8 9 Next
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