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(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.
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