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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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