-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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011