- 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 imposedPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007