Aaron T. and Linda K. Ball - Page 7

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               Petitioners state in their petition that they were denied              
          their right to a face-to-face hearing as provided in section                
          6330.  We have held that it would be unproductive and thus                  
          unnecessary to remand a case for a face-to-face hearing if                  
          petitioners merely want to advance frivolous arguments.  See                
          Lunsford v. Commissioner, 117 T.C. 183, 189 (2001); Stephens v.             
          Commissioner, T.C. Memo. 2005-183; Balice v. Commissioner, T.C.             
          Memo. 2005-161.                                                             
               In numerous letters to respondent, in their petition, and at           
          trial, petitioners argued that they had no income and were not              
          liable for income taxes.  Petitioners also argued that they                 
          received no valid notice of deficiency because the notice that              
          they received was not signed by the Secretary of the Treasury.              
          These arguments are characteristic of tax-protester rhetoric that           
          has been universally rejected by this and other courts.2  Michael           
          v. Commissioner, T.C. Memo. 2003-26; Knelman v. Commissioner,               
          T.C. Memo. 2000-268, affd. 33 Fed. Appx. 346 (9th Cir. 2002).               
          Because petitioners insisted upon making only these frivolous               
          arguments, we decline to remand this case to respondent so that             
          petitioners may have a face-to-face hearing.3                               

               2  Petitioners made these arguments in filings and at trial            
          even though the underlying tax liability was not properly an                
          issue in this case.                                                         
               3  Respondent offered petitioners a face-to-face hearing if            
          petitioners raised any meaningful issue regarding the proposed              

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