-9-
for abuse of discretion. See Goza v. Commissioner, 114 T.C. 176,
181-182 (2000); Sego v. Commissioner, 114 T.C. 604, 610 (2000).
The record establishes that the Appeals Office properly
verified that all applicable laws and administrative procedures
were followed. Appeals Officer Freitag had no prior involvement
with respect to the unpaid tax liabilities before the section
6330 hearing. The Form 4340 shows that proper assessments were
made and that requisite notices had been sent to petitioners.
Petitioners raised no viable claims of procedural irregularities,7
and respondent properly relied on the Form 4340 during the
administrative process. See Nestor v. Commissioner, supra.
Petitioners were given the opportunity to but did not discuss
collection alternatives at the sec. 6330 hearing.
Petitioners’ contentions are frivolous and groundless and
will not be refuted with copious citation and extended
discussion.8 See Williams v. Commissioner, 114 T.C. 136, 138-139
7Petitioners’ request to record the sec. 6330 hearing is
discussed below.
8Petitioners’ contentions are substantially similar to
contentions raised by the taxpayer in Hiland v. Commissioner,
T.C. Memo. 2004-225 (“Taxpayer’s complaints with respect to the
administrative proceedings included the following: No legitimate
hearing under sec. 6330 ever took place; taxpayer was denied the
opportunity to raise issues he deemed “relevant” (e.g., the
“existence” of the underlying tax liability); and cited
documentation had not been produced and/or addressed (e.g.,
record of the assessments, statutory notice and demand for
payment, any “valid notice of deficiency”, and verification from
the Secretary that all applicable requirements were met))”. In
(continued...)
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