Nicholas & Carrie Cozzens - Page 9

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               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            
               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-           

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