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explanation of disagreement containing frivolous and groundless
arguments, including that he could not find any statute making
him liable for the taxes in issue and that he has no liability
for “income taxes”.
On March 22, 2004, respondent mailed petitioner a letter
advising petitioner that respondent had received petitioner’s
hearing request and that the issues and arguments he raised in
his hearing request are of the kind that courts have determined
are frivolous or groundless. In this letter, respondent directed
petitioner to a document entitled “The Truth About Frivolous Tax
Arguments” and a link to an IRS Web site containing this
document. Respondent scheduled a telephonic hearing for April 8,
2004, at 1 p.m. The letter further advised petitioner that if
the Appeals Office did not receive any further information from
petitioner or petitioner was not available when called for the
scheduled hearing, his case would be reviewed based on the
information in petitioner’s file.
On April 7, 2004, in response to respondent’s March 22,
2004, letter, a letter was mailed to respondent demanding a face-
to-face hearing. In the April 7, 2004, letter, petitioner did
not list any spousal defenses or collection alternatives, and he
did not list any nonfrivolous arguments regarding the
appropriateness of collection actions or his underlying tax
liabilities.
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Last modified: May 25, 2011