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website containing this document.2 Settlement Officer Feist also
advised petitioner that he could not dispute his underlying
liabilities for the years in issue because he received notices of
deficiency for the years in issue.
On June 18, 2004, petitioner called Settlement Officer
Feist. Petitioner and Settlement Officer Feist agreed to
postpone the section 6330 hearing until July 8, 2004. During the
telephone call of June 18, 2004, petitioner requested a face-to-
face section 6330 hearing and to record the section 6330 hearing.
Settlement Officer Feist again noted petitioner’s previous
frivolous arguments, but left open the possibility for a face-to-
face and recorded section 6330 hearing if petitioner would
provide him with relevant issues he wished to discuss.
On or about June 21, 2004, respondent received a fax from
petitioner. In the fax, petitioner acknowledged the June 22,
2004, deadline for submission of relevant issues and stated that
he intended to have a face-to-face section 6330 hearing, bring
witnesses, and record the section 6330 hearing with a court
reporter and tape recorder.
2 This document concludes with six pages devoted to
penalties for pursuing frivolous tax arguments including citation
to sec. 6673 and citation to and discussion of numerous cases,
including sec. 6330 collection cases and other cases, where the
Court has imposed penalties on taxpayers for advancing frivolous
arguments.
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Last modified: May 25, 2011