Robert E. Crandall - Page 8

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               courts have continuously rejected, that there is no                    
               reason for remanding your case to appeals to hold a                    
               face to face hearing and waste your time, Appeals’                     
               time, and the taxpayers’ money to simply allow you to                  
               document on a tape all of your frivolous arguments.                    
                    So the question is as I noted in the * * *                        
               [order], do you have any issues which I have authority                 
               to consider, and which Appeals had authority to                        
               consider at your hearing which you want to raise, and                  
               presumably would have raised at the hearing had you                    
               been given a chance to have the hearing.                               
                    An that’s why I denied the government’s motion,                   
               because they did deny you your rights, and we don’t                    
               know whether--I don’t know whether you have any                        
               legitimate issue to raise or not.  So that is what you                 
               have to address here.                                                  
               Petitioner responded with:  “Well, my position is that the             
          hearing was denied, and that I was not able to bring up the                 
          issues that I outlined in a letter when requesting my letter for            
          certain documents, and et cetera, to be available, and for the              
          government to have at the hearing.  Those were issues that I                
          wanted to discuss with them.”  The Court again reiterated that              
          such contentions had been ruled meritless, and warned petitioner:           
          “Making those arguments, and continuing to make those arguments,            
          and costing the taxpayers a lot of money for me to deal with                
          them, may result in the application of additional penalties under           
          Section 6673.”  Petitioner’s remaining comments failed to                   
          identify any specific colorable issues for remand and consisted             
          principally of vague recitations or paraphrases of the statutory            

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