Robert Holliday - Page 1

                                 T.C. Memo. 2005-132                                  

                               UNITED STATES TAX COURT                                

                           ROBERT HOLLIDAY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18974-03L.            Filed June 1, 2005.                   

                    P filed a petition for judicial review pursuant to                
               sec. 6330, I.R.C., in response to a determination by R                 
               to proceed with collection by lien of assessed income                  
               tax liabilities for 1991, 1992, and 1993.  P filed                     
               joint returns with his spouse for these years that                     
               reported total income of “$0” and a total tax of “$0”                  
               on all three of the returns, to which were attached                    
               identical lengthy documents that contained contentions                 
               and arguments that are frivolous and/or groundless.  P                 
               filed with the IRS a Request for a Due Process Hearing,                
               to which was attached a document raising several                       
               reasons for P’s disagreement with a proposed IRS                       
               collection action.  P continues to pursue these issues,                
               all of which are refuted by the record and/or holdings                 
               in prior cases.                                                        
                    Held:  Remanding this matter to respondent’s                      
               Appeals Office for recording would be neither necessary                
               nor productive.                                                        

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