Michael Balice - Page 10

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          groundless. See Abrams v. Commissioner, 82 T.C. 403, 409-413                
          (1984); White v. Commissioner, 72 T.C. 1126, 1135-1136 (1979).              
               We have considered all of petitioner’s statements,                     
          contentions, arguments, and requests that are not discussed                 
          herein, and, to the extent we have not found them to be frivolous           
          and/or groundless, we find them to be without merit and/or                  
          irrelevant.6                                                                
               On the record before us, we shall grant respondent’s motion.           
               To reflect the foregoing,                                              
                                             An order granting respondent’s           
                                        motion and decision for respondent            
                                        will be entered.                              

               6We shall, however, address one of petitioner’s arguments in           
          petitioner’s response.  Petitioner argues in petitioner’s                   
          response that the Appeals officer did not provide him with the              
          summary record of assessment with respect to petitioner’s unpaid            
          liability for 1996.  Respondent is not required to provide                  
          petitioner with the summary record of assessment.  See Koff v.              
          United States, 3 F.3d 1297, 1298 (9th Cir. 1993); Roberts v.                
          Commissioner, 118 T.C. 365, 370 n.7 (2002), affd. 329 F.3d 1224             
          (11th Cir. 2003).                                                           
               While not altogether clear, petitioner may also be arguing             
          that respondent’s collection action with respect to petitioner’s            
          taxable year 1996 may not be valid because he did not receive               
          certain documentation to which he is entitled under sec. 6203 and           
          sec. 301.6203-1, Proced. & Admin. Regs.  On the record before us,           
          we reject any such argument.  On Nov. 6, 2003,  respondent issued           
          to petitioner a notice of tax lien.  The third page of the notice           
          of tax lien set forth, inter alia, petitioner’s name, the date of           
          assessment, the character of the liability assessed, the taxable            
          period, and the total of the amounts assessed.  We conclude that            
          petitioner received the documentation to which he is entitled               
          under sec. 6203 and sec. 301.6203-1, Proced. & Admin. Regs.  See            
          Roberts v. Commissioner, supra.                                             




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