Denis J. Faris and Carolyn M. Faris - Page 7

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          petitioners are precluded from challenging the existence or                 
          amount of the underlying tax liabilities for 1997 and 1998.  See            
          sec. 6330(c)(2)(B); Sego v. Commissioner, supra; Goza v.                    
          Commissioner, supra.  We review respondent’s determination for              
          abuse of discretion.  See Sego v. Commissioner, supra at 610.               
               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 in            
          their briefs, petitioners advanced shopworn arguments                       
          characteristic of tax-protester rhetoric that has been                      
          universally rejected by this and other courts.  Wilcox v.                   
          Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo.               
          1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir.             
          1986); Charczuk v. Commissioner, 771 F.2d 471 (10th Cir. 1985),             
          affg. T.C. Memo. 1983-433; Michael v. Commissioner, T.C. Memo.              
          2003-26; Knelman v. Commissioner, T.C. Memo. 2000-268, affd. 33             
          Fed. Appx. 346 (9th Cir. 2002).  We shall not painstakingly                 
          address petitioners’ assertions “with somber reasoning and                  






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