- 7 - Commissioner, 117 T.C. 183, 189 (2001), the Court declined to remand the case to the Appeals Office for a hearing because the taxpayer could not prevail on any of the issues he had raised in the proceeding. As a result, we held that it was neither necessary nor productive to remand the case to the Appeals Office. Id.; see Kemper v. Commissioner, T.C. Memo. 2003-195 (remand to record face-to-face hearing denied); see also Keene v. Commissioner, 121 T.C. 8, 19-20 (2003). The same reasoning applies here. During the trial, petitioner stated that his only arguments for overturning respondent’s determination were those stated in his request for a collection due process hearing and a letter petitioner wrote to the Director of the Internal Revenue Service Center on June 18, 2003, challenging the Government’s authority to issue a notice of deficiency to him. Petitioner cannot prevail on any of those arguments. His arguments about respondent’s assessment procedures are frivolous. We conclude that it is not necessary and would not be productive to remand the case to the Appeals Office to hold a face-to-face hearing. Thus, respondent may proceed with a levy with respect to petitioner’s 2000 tax year.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011