- 9 - filed Notice of Federal Tax Lien. This determination was made because the taxpayers failed to raise any relevant issue, offer a collection alternative, or present any reason to justify withdrawal. Therefore, the determination by Appeals balances the need for efficient collection of taxes with the taxpayer’s legitimate concern that any collection action be no more in [sic] intrusive than necessary. In response to the notice of determination, petitioners filed with the Court a petition with attachments that we consider to be part of the petition. Except for an argument under section 7521(a)(1), the petition and the attachments thereto contained statements, contentions, arguments, and requests that the Court finds to be frivolous and/or groundless.5 With respect to sec- tion 7521(a)(1), petitioners alleged that the Appeals Office refused to allow them to make an audio recording of the Appeals Office hearing that the settlement officer had scheduled on November 27, 2002, and that that refusal was improper under that section. Discussion The Court may grant summary judgment where there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 5The frivolous and/or groundless statements, contentions, arguments, and requests in petitioners’ petition and the attach- ments to that petition are very similar to the frivolous and/or groundless statements, contentions, arguments, and requests in the respective petitions filed with the Court by certain other taxpayers. See, e.g., Guerrier v. Commissioner, T.C. Memo. 2002- 3.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011