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to-face meeting with petitioner on December 3, 2004, and
petitioner continued to raise only frivolous arguments.
Respondent reported that petitioner raised the following
arguments: (1) Whether respondent had issued a valid notice of
deficiency; (2) whether wages are taxable income; (3) whether
respondent is required to show that the requirements of any
applicable law or administrative procedure had been met; (4)
whether respondent is required to provide documentation of
delegation orders from the Secretary; (5) whether the underlying
assessment is valid; and (6) whether petitioner received a valid
notice and demand. The Court also filed petitioner’s status
report that confirmed that a section 6330 hearing was held on
December 3, 2004. In the status report, petitioner argued that
the hearing was not impartial, that petitioner’s arguments are
not frivolous, and that respondent has not addressed “apparent
irregularities in the Irs’ [sic] assessment procedures.”
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). The Court may grant
summary judgment when there is no genuine issue of material fact
and a decision may be rendered as matter of law. Rule 121(b);
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.
17 F.3d 965 (7th Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753,
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