William B. and Diane S. Meyer - Page 9

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         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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