John J. Delgado - Page 4

                                        - 4 -                                         
          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            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011