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