- 8 -
administrative process and in his petition to this Court were
frivolous tax protester type arguments. We do not address
petitioner’s frivolous arguments with somber reasoning and
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).
To the extent petitioner complains of not receiving 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, 117 T.C. 183, 189 (2001).
Petitioner was not current in filing his income tax returns,
having failed to file for taxable years 1999, 2003, and 2004.
Petitioner was not eligible for, nor did he submit, any
collection alternatives.
We conclude that, although the telephonic conference
terminated prematurely, petitioner did receive a hearing as
required by sections 6320(b) and 6330(c)(3).2 Mrs. Magee
verified that all applicable laws and administrative procedures
had been met, that she had not had any prior involvement with
respect to petitioner’s tax liability, and that the proposed
collection activity was no more intrusive than necessary.
2Although petitioner’s request for a hearing was pursuant to
sec. 6320, sec. 6320(c) provides that sec. 6330(c) applies.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: November 10, 2007