- 4 - frivolous and directed petitioner to a publication entitled “The Truth About Frivolous Tax Arguments” available on the Internal Revenue Service’s Web site. Petitioner quickly responded to Mr. Bethea, and in a letter dated November 11, 2005, raised his frivolous tax protester arguments and attached his frivolous amended return claiming he did not owe taxes for 1998. Petitioner also informed Mr. Bethea in this letter: “I have responded to you with this letter so a telephone conference is not necessary.” Mr. Bethea considered the documents petitioner sent during the section 6330 administrative process, concluded that petitioner’s contentions were frivolous and that petitioner did not offer any collection alternatives, and on December 22, 2005, sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, sustaining the proposed levy to collect petitioner’s 1998 tax liabilities. Petitioner timely petitioned this Court. On May 18, 2006, respondent filed the instant motion for summary judgment and to impose a penalty pursuant to section 6673. On June 15, 2006, petitioner filed a response. Discussion Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials and may be granted where there is no genuine issue of material fact and a decision may bePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011