Robert William Woods - Page 7

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          challenges to the appropriateness of collection actions, and                
          collection alternatives.  Sec. 6330(c)(2)(A).  The person may               
          challenge the existence or amount of the underlying tax if the              
          person did not receive any statutory notice of deficiency for the           
          tax liability or did not otherwise have an opportunity to dispute           
          the tax liability.  Sec. 6330(c)(2)(B).                                     
               Where the validity of the underlying tax liability is                  
          properly in issue, the Court will review the matter de novo.                
          Where the validity of the underlying tax is not properly in                 
          issue, however, the Court will review the Commissioner’s                    
          administrative determination for abuse of discretion.  Sego v.              
          Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114           
          T.C. 176, 181-182 (2000).                                                   
               Petitioner did not dispute at his Appeals hearing that he              
          received the notices of deficiency.  Petitioner argued, during              
          the Appeals hearing and throughout the administrative process               
          with the IRS, that he did not have taxable income under sections            
          861, 911, and section 1.861-8(a)(4), Income Tax Regs.  That                 
          argument has been rejected by every court that has addressed the            
          issue and is the type of frivolous argument that wastes the                 
          Court’s time and resources.4  We do not address petitioner’s                

               4 In two letters to respondent dated July 31 and Sept. 16,             
          2002, petitioner claims that he is not a tax protester and that             
          he has never made a ridiculous claim regarding the law.                     
          Petitioner informed respondent that he was a member of N.I.T.E.             
                                                             (continued...)           





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