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the errors allegedly committed by respondent or a statement of
facts that form the basis of petitioner’s assignments of error.
Petitioner failed to allege any facts that indicate that
respondent abused his discretion in determining that it is
appropriate to levy on petitioner’s property and to file a notice
of Federal tax lien.
We find that petitioner’s claims state no justiciable basis
on which this Court may grant him relief. Petitioner claims that
“administrative judgment by estoppel” and the Uniform Commercial
Code (U.C.C.) provide him with relief. The U.C.C. argument he
asserts is similar to the argument that petitioner advanced in a
prior proceeding for the 1999 taxable year. In Forbes v.
Commissioner, docket No. 15591-03L, this Court found that
petitioner’s argument was frivolous and groundless. We find that
the petition, the amended petition, and other documents
petitioner has filed contain only incoherent arguments and
meaningless legalistic language. “A petition that makes only
frivolous and groundless arguments makes no justiciable claim,
and it is properly subject to a motion for judgment on the
pleadings.” Nis Family Trust v. Commissioner, 115 T.C. 523, 539
(2000). Therefore, we shall grant respondent’s motion to
dismiss. See Funk v. Commissioner, 123 T.C. 213, 216-217 (2004)
(finding that a petition and an amended petition failed to state
a claim upon which relief could be granted when they lacked a
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