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Petitioner’s pretrial memorandum contained frivolous and
groundless arguments. Respondent’s pretrial memorandum again
warned petitioner about the section 6673 penalty for making
frivolous arguments to the Court.
On May 18, 2007, petitioner filed a statement containing
frivolous and groundless arguments. Petitioner’s statement also
contained disparaging and disrespectful statements directed to
the Court. That same day, petitioner filed a voluminous document
entitled “Petitioner’s Motions” which was replete with frivolous
and groundless tax-protester arguments.
On May 30, 2007, the Court denied “Petitioner’s Motions”.
OPINION
I. Determination To Proceed With Collection
Section 6330(a) provides that the Secretary shall furnish
taxpayers with written notice of their right to a hearing before
any property is levied upon. Section 6330 further provides that
the taxpayer may request administrative review of the matter (in
the form of a hearing) within a 30-day period. Sec. 6330(a) and
(b).
Pursuant to section 6330(c)(2)(A), a taxpayer may raise at
the section 6330 hearing any relevant issue with regard to the
Commissioner’s collection activities, including spousal defenses,
challenges to the appropriateness of the Commissioner’s intended
collection action, and alternative means of collection. Sego v.
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Last modified: November 10, 2007