W. James Kubon - Page 6

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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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