Bradley W. Bean - Page 10

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          Commissioner, T.C. Memo. 2004-17; Armstrong v. Commissioner, T.C.           
          Memo. 2002-224.  Thus, a face-to-face hearing is not invariably             
          required.                                                                   
               Respondent sent three letters to petitioner stating that he            
          would be allowed a face-to-face hearing if he would advise                  
          respondent of the relevant issues he wished to discuss.                     
          Petitioner responded to two of those letters, but did not raise             
          any relevant issues.  Petitioner was also given the opportunity             
          to have a telephone hearing but did not participate.                        
          Additionally, petitioner did not submit any documentation to                
          respondent to be considered in an administrative review of his              
          file.                                                                       
               Because no hearing had been conducted, we declined to grant            
          respondent’s motion for summary judgment.  The record as it then            
          existed did not foreclose the possibility that petitioner might             
          have raised valid arguments had a hearing been held.                        
          Accordingly, we provided petitioner an opportunity before the               
          Court to identify any relevant issues he wished to raise that               
          could warrant further consideration of the merits of his case by            
          respondent or this Court.  Petitioner, however, failed to offer             
          any relevant issues of merit.                                               
               In the light of the above and in consideration of                      
          petitioner’s frivolous arguments, discussed infra, a face-to-face           
          hearing in this case would not have been, nor would it be,                  






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