-6-
cooperate with respondent’s Appeals officer, Taylor v.
Commissioner, T.C. Memo. 2004-25, affd. 130 Fed. Appx. 934 (9th
Cir. 2005); where a taxpayer requests an Appeals Office hearing
to cause delay, Nestor v. Commissioner, T.C. Memo. 2002-251
(2002); or where a taxpayer raises frivolous issues and
arguments, id.
While petitioner has not raised frivolous issues, petitioner
did cause delay and has refused to identify any specific issues
in spite of repeated requests and opportunities to do so. At
least one other taxpayer was unsuccessful in using delaying
tactics similar to those petitioner now uses. See Ho v.
Commissioner, T.C. Memo. 2006-41.
On the available administrative record, we conclude that
respondent’s Appeals Office did not abuse its discretion in
making a determination sustaining respondent’s notice of levy
where petitioner herein did not identify specific issues relevant
to an Appeals Office hearing, did not give the Appeals officer a
reasonable explanation as to why issues could not be identified
prior to the hearing, and did not participate in the offered
telephonic hearing.
Other arguments raised by petitioner have been considered
and are rejected.
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