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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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