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assignment of error.” See Lunsford v. Commissioner, 117 T.C. 183
(2001); Goza v. Commissioner, 114 T.C. 176 (2000).
The petition in the instant case does not contain clear and
concise assignments of any error that petitioner alleges to have
been committed in the notice of determination. Likewise, the
petition does not contain clear and concise lettered statements
of the facts on which petitioner bases an assignment of error.
Instead, petitioner argues only law and legal conclusions in the
petition as evinced by the attachments to the petition.
The petition neither conforms to this Court’s Rules of
Practice and Procedure, nor states a claim upon which relief can
be granted.2 The absence in the petition of specific justiciable
allegations of error and of supporting facts permits this Court
to grant respondent’s motion. See Goza v. Commissioner, supra.
2Petitioner’s contention that he is entitled to a face-to-
face hearing has no merit. Hearings conducted under sec. 6330
are informal proceedings, not formal adjudications. Katz v.
Commissioner, 115 T.C. 329, 337 (2000); Davis v. Commissioner,
115 T.C. 35, 41 (2000). Hearings may be held as face-to-face
meetings, and they may also be conducted by telephone or by
correspondence. Katz v. Commissioner, supra at 337-338; sec.
301.6330-1(d)(2), Q&A-D6 and D7, Proced. & Admin. Regs.
In light of petitioner’s frivolous arguments, a face-to-face
hearing in this case would not be productive. See Lunsford v.
Commissioner, 117 T.C. 183, 189 (2001). We note that respondent
offered a face-to-face hearing if petitioner raised any
meaningful issue regarding his tax liability or the proposed
levy.
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