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copious citations of precedent, as to do so might suggest that
these arguments possess some degree of colorable merit. See
Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
For example, petitioner contended that the NFTLs are
“counterfeited securities”. Likewise, he contended that the
Notice of Determination was fraudulent because it does not carry
a proper number from the Office of Management and Budget.
Amongst others, he has also raised the well-worn argument that he
is not subject to or required to pay any income tax unless the
Commissioner or his agents can show him a statute that expressly
states that he is subject to tax.
To the extent petitioner complains that he did not receive a
face-to-face hearing, this Court has held that it is neither
necessary nor productive to remand cases to an Appeals Office for
face-to-face hearings when a taxpayer raises only frivolous
arguments. Lunsford v. Commissioner, supra at 189.
The arguments or information expressed by petitioner in the
telephonic conference were, at best, superficial and did not go
to the merits of the underlying 2001 tax liability. Instead and
true to form, petitioner posed the well-worn protester sophistry
that he would gladly pay the tax if someone could identify the
statute that makes him liable to pay. The only other matter
raised by petitioner was his request that the Appeals officer
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