- 12 -
Commissioner, T.C. Memo. 2006-88; Ho v. Commissioner, T.C. Memo.
2006-41; Leineweber v. Commissioner, T.C. Memo. 2004-17.
Petitioner repeatedly asserted frivolous and groundless
arguments regarding all of his unpaid tax liabilities throughout
the section 6330 hearing process and at trial. The Appeals
Office offered petitioner the right to conduct his section 6330
hearing by telephone and/or through written correspondence. The
Appeals Office also advised petitioner on several occasions that
it would grant petitioner’s request for a face-to-face hearing if
petitioner identified relevant issues he wanted to discuss. In
lieu of identifying relevant issues, petitioner continually
responded with more frivolous arguments and refused to
participate in a telephone hearing. At no time did petitioner
identify any relevant issue he would discuss if granted a face-
to-face hearing.
With respect to petitioner’s 1996, 1997, and 1998
liabilities, we hold that respondent did not err in refusing to
grant petitioner a face-to-face hearing, and we sustain
respondent’s proposed collection action.
B. 2000
Section 6330(c)(1) provides that a hearing officer, during a
section 6330 hearing, shall “obtain verification from the
Secretary that the requirements of any applicable law or
administrative procedure have been met.” The obligation imposed
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: November 10, 2007