Kevin M. Moore - Page 5

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          duty to file income tax returns--have no merit and are frivolous.           
          The revenue ruling, under the heading “CIVIL AND CRIMINAL                   
          PENALTIES”, notes that in addition to several other potential               
          penalties, taxpayers may be liable for “a penalty of up to                  
          $25,000 under section 6673 if the taxpayer makes frivolous                  
          arguments in the United States Tax Court.”  Id., 2006-1 C.B. at             
          746.  On the face of the revenue ruling petitioner wrote that he            
          had read the revenue ruling.  Petitioner attached a document                
          containing frivolous and groundless arguments to the revenue                
               On August 3, 2006, respondent issued a Notice of                       
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (notice of determination) to petitioner regarding his           
          1997, 1998, 1999, 2000, 2001, and 2002 tax years.  In the notice            
          of determination, respondent determined that the proposed                   
          collection action was appropriate, petitioner failed to submit a            
          viable collection alternative, and collection should proceed.  In           
          an attachment to the notice of determination, respondent referred           
          petitioner to “The Truth About Frivolous Tax Arguments” and                 
          provided an Internet address to access the document.                        
               On May 16, 2007, the Court held a trial in this matter.                
          That same day, the Court filed respondent’s and petitioner’s                
          pretrial memoranda.  In his pretrial memorandum, petitioner                 
          stated that he did not intend to call any witnesses.                        

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