Dale Kinslow - Page 9

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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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