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On June 28, 2005, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 to petitioner regarding his 2001 tax year. In the
notice of determination, respondent determined to sustain the
collection action.
On July 25, 2005, petitioner timely filed a petition
regarding the notice of determination. The petition contains
frivolous and groundless arguments.
On January 31, 2006, in response to petitioner’s lengthy and
frivolous discovery requests, respondent sent petitioner a letter
providing him excerpts from “The Truth About Frivolous Tax
Arguments”.
On July 5, 2006, respondent sent petitioner a letter that
noted that petitioner’s continuing discovery requests were
frivolous and groundless, and it appeared that their only purpose
was for delay. Petitioner was advised of the provisions of
section 6673 and that respondent would file a motion requesting
sanctions under section 6673.
On July 19, 2006, respondent sent petitioner another letter.
Attached were copies of his Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters, for 2001; a
summary record of assessments for 2001; and “The Truth About
Frivolous Tax Arguments”. Respondent directed petitioner’s
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Last modified: November 10, 2007