- 10 - constituted a deliberate refusal of delivery and repudiation of his opportunity to contest the liability determined in the notice of deficiency. The provisions in section 6330(c)(2)(B) limiting in collection due process cases the right to contest the underlying tax liability are clearly designed to prevent the creation of a prepayment remedy in cases like this one. The validity of the underlying tax liability therefore cannot be properly raised by petition in this case. We will not spend time discussing petitioner’s Cross- Motion to Dismiss on the grounds that the Tax Court lacks jurisdiction “to address the particular notice of deficiency upon which this Docket is based.” In his motion, petitioner continues on for pages making spurious and ridiculous arguments in support of his motion. We will not waste our time addressing them as they are meritless, timeworn protester arguments that have been rejected and discredited by this Court and the other Federal courts. For this reason, petitioner’s motion will be denied. Respondent’s Motion for Summary Judgment filed on August 11, 2005, will be granted and respondent’s administrative determination to proceed with collection against petitioner will be sustained. Petitioner’s Motion to Dismiss filed on November 14, 2005, will be denied.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011