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On April 13, 2004, respondent issued to petitioner the
decision letter. The decision letter advised petitioner that
respondent reviewed the proposed collection action for 1994,
1995, 1996, and 1997 and that petitioner received an equivalent
hearing because he did not file a request for a section 6330
hearing within the time prescribed under section 6320 and/or 6330
in order to receive a section 6330 hearing. The decision letter
further stated that petitioner did not raise any issues that were
relevant to paying his tax liability but that petitioner raised
only frivolous issues. The decision letter also stated that
petitioner had no right to dispute the decision of the Appeals
officer in court, cited Pierson v. Commissioner, 115 T.C. 576
(2000), to petitioner, and warned petitioner that if he appealed
the decision letter to the Tax Court, the Court is empowered to
impose sanctions up to $25,000 for instituting or maintaining an
action primarily for delay or taking a position that is frivolous
or groundless.
Petitioner petitioned the Court to dispute the decision
letter. Respondent filed a motion to dismiss for lack of
jurisdiction. Petitioner filed a response to respondent’s motion
to dismiss for lack of jurisdiction. Respondent filed a response
to petitioner’s response to respondent’s motion to dismiss for
lack of jurisdiction.
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Last modified: May 25, 2011