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T.C. 1, 8-9 (2004). Because the tax liability due is one
petitioner reported due on his return, he did not receive a
notice of deficiency or otherwise have an opportunity to dispute
the 1998 tax liability.
For the validity of the 1998 underlying tax liability to be
properly at issue, petitioner must comply with Rule 331. His
pleading must contain a sufficient specificity of facts so that
the Court can conduct a meaningful hearing to determine whether
respondent can proceed with collection. Petitioner has failed to
comply with Rule 331. He has not identified items of income,
deduction, or credit, or the computations that are incorrect.
Poindexter v. Commissioner, 122 T.C. 280, 285 (2004).
Petitioner was told repeatedly by the Appeals officer that
the arguments raised in his request for a hearing were considered
irrelevant and frivolous by the Internal Revenue Service and this
Court. Petitioner insisted in pursuing these arguments and
failed to assert any other issues, such as the ones listed in
section 6330(c)(2)(A). In particular, petitioner never made an
offer of an alternative means of collection during the Appeals
process. We therefore find that petitioner has raised no issue
that would warrant a remand to the Appeals Office for another
hearing. See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001);
Kemper v. Commissioner, T.C. Memo. 2003-195.
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