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to-face hearings if only items subject to discussion
include items that are frivolous such as those
attributed to moral, religious, political,
constitutional, conscientious, or similar grounds.
Petitioner never raised any of these issues, the issue
raised by petitioner is tax liability. Nowhere in the
“THE TRUTH ABOUT FRIVILOUS [sic] TAX ARGUMENTS” is tax
liability listed. * * *
Discussion
A decision granting summary judgment may be rendered if the
pleadings and other materials in the record show that there is no
genuine issue as to any material fact and that a decision may be
rendered as a matter of law. Rule 121(b); Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir.
1994). We have considered the pleadings and other materials in
the record and conclude that there is no genuine issue of any
material fact and that a decision may be rendered as a matter of
law.
Petitioner argues that respondent erred by not allowing
petitioner to challenge the merits of the underlying tax
liability, by not conducting a face-to-face hearing, and by
limiting the subject matter that could be discussed during the
hearing.
When petitioner received a notice of deficiency, he did not
follow the specific instructions contained in the notice which
allowed him to petition this Court if he disagreed. Instead,
petitioner sent a letter to respondent, the Secretary of the
Treasury, the Chairman of the Senate Finance Committee, the
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