- 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 arguments.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011