- 11 - taxpayer may raise, and the hearing officer must consider, relevant issues raised by the taxpayer in a section 6330 hearing. See sec. 6330(c)(2). However, it is well established that the Commissioner and the courts need not consider or refute frivolous arguments with copious citation and extended discussion. Williams v. Commissioner, 114 T.C. 136, 138-139 (2000) (citing Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984)). Mr. Climan provided petitioner a meaningful opportunity to present relevant, nonfrivolous arguments why the levy should not be allowed to proceed, but petitioner repeatedly refused to provide any such arguments or information necessary to support them. Mr. Sample made several requests for information regarding petitioner’s financial condition both before and during the hearing, but petitioner failed to provide any such information. Accordingly, we find that Mr. Sample did not abuse his discretion in terminating petitioner’s section 6330 hearing. There is a limit to the tax system’s tolerance for unproductive and frivolous exchanges regarding a taxpayer’s obligations to file returns and pay tax. Kolker v. Commissioner, T.C. Memo. 2004- 288. On this record, we conclude that there is no genuine issue of material fact requiring a trial in this case, and we hold that respondent is entitled to the entry of a decision sustaining the proposed levy as a matter of law.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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