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