Michael Jack Stephens - Page 5

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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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