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information petitioner wished to have considered in the hearing.
The letter requested a response by September 7, 2005.
On September 13, 2005, petitioner sent respondent a letter
captioned “LEGAL NOTICE”, in which petitioner asserted only
frivolous arguments. Petitioner also sent a second letter
containing frivolous arguments. All of the arguments petitioner
raised in those letters were also raised in the 12-page amended
petition filed with this Court in petitioner’s deficiency case at
docket No. 14262-05. On October 6, 2005, this Court struck, sua
sponte, paragraphs 5 through 50 and 78 through 139 of the
petition in that case as frivolous and advised petitioner
regarding section 6673(a)(1).
Based on the administrative file and correspondence,
respondent’s Appeals officer determined that the proposed levy
was appropriate and sent petitioner a notice of determination.
Petitioner timely petitioned this Court pursuant to section 6330.
Petitioner’s lengthy petition and reply to respondent’s answer
raise only frivolous arguments. Respondent filed a motion for
summary judgment and to impose a penalty pursuant to section 6673
on August 18, 2006.
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials and may be granted where
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