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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