- 10 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011