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productive. See Lunsford v. Commissioner, 117 T.C. 183, 189
(2001); Ho v. Commissioner, supra.
Additionally, petitioner argues that respondent abused his
discretion by failing to verify that all administrative
procedures have been met. However, in the notice of
determination, the Appeals officer verified that all requirements
of applicable law and administrative procedure had been met, and
he properly balanced the need for efficient collection against
the intrusiveness of the collection action. Petitioner points to
nothing that indicates respondent failed to follow applicable law
and administrative procedure.
Petitioner further argues that respondent abused his
discretion by failing to make a notice and demand for payment.
However, the Forms 4340 indicate that notices and demands for
payment were made.
Petitioner also raises various tax-protester arguments,
including: (1) The income tax is unconstitutional; (2) he is not
a U.S. citizen, but instead “an American man living on the soil
of Massachusetts”; (3) letters received from respondent do not
include signatures or “Publication No. 594”; and (4) he has not
been provided with proof that the person(s) who issued the notice
of Federal tax lien had the authority to do so. Petitioner’s
arguments have been rejected by this Court and other courts, and
“We perceive no need to refute these arguments with somber
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