- 8 - (iii) offers of collection alterative, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise. Petitioner singularly argued, both in his petition and at his CDP hearing, that he was not obligated to pay his Federal income taxes because respondent had failed to provide him with the law providing as such, and because the Federal tax system is inherently unfair. As we have previously discussed, Rule 331(b)(4) expressly requires that petitioner provide a clear assignment of errors with respect to respondent’s notice of determination. The underlying petition was silent as to any errors made by respondent, and petitioner continued to raise his singular challenge based on the veracity and fairness of the Federal tax system at his CDP hearing. Accordingly, and pursuant to section 6330(c)(2)(A), we must hold that petitioner conceded all other issues related to the proposed collection action. IV. Penalty for Maintaining Frivolous Arguments Petitioner has been on notice since at least 2000 that his arguments concerning his income and his liability for income tax are frivolous.1 However, despite this notice, petitioner has repeatedly maintained his arguments to respondent and the Court. 1 Respondent sent petitioner numerous copies of an article entitled “The Truth About Frivolous Tax Court Arguments”, both prior to the date that Kinslow v. Commissioner, T.C. Memo. 2002- 313, was filed and as part of the present CDP case.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011