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taxpayers had advanced were frivolous and groundless, it was not
necessary to remand the taxpayers' case to the Office of Appeals
so that a second conference airing the contentions could be audio
recorded.
Petitioner was questioned by the Court at the hearing on
respondent's motion for summary judgment concerning the issues he
wished to raise at a conference on remand. Petitioner stated
that the issues were the same as those listed in his request for
a hearing, as well as an innocent spouse claim on behalf of Mrs.
Schwersensky. As discussed above, the issues raised in
petitioner's hearing request are all frivolous and/or groundless.
As for the innocent spouse claim, Mrs. Schwersensky's entitlement
to relief under section 6015 is irrelevant to this case, which
concerns only whether respondent may proceed with his collection
action against petitioner.10 The remaining arguments raised by
petitioner are nothing more than tax protester rhetoric and
legalistic gibberish.11 We do not address such arguments with
somber reasoning and copious citations of precedent, as to do so
might suggest that they possess some colorable merit. See Crain
v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
10 Mrs. Schwersensky failed to petition this Court within 30
days of respondent's notice of determination as to her. See sec.
6330(d)(1); cf. Moorhous v. Commissioner, 116 T.C. 263, 271
(2001) (jointly filing spouses are not a single "person" for
purposes of sec. 6330).
11 See supra notes 4, 6, and 7.
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