- 7 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 Next
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