Loran J. Forbes - Page 4

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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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