Edward W. Clough - Page 12

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         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             

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