Kevin M. Moore - Page 6

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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”.              
          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            
               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