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citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984); see, e.g., Wetzel v.
Commissioner, T.C. Memo. 2005-211 (rejecting as frivolous the
argument that the taxpayer was not a taxpayer); Nunn v.
Commissioner, T.C. Memo. 2002-250 (rejecting as without merit the
argument that the Commissioner had no jurisdiction over the
taxpayer or his documents). This Court rejects petitioner’s
tax-protester arguments as frivolous and without merit.
Petitioner contended that Mr. Dolin concluded the conference
before collection alternatives could be discussed. However,
throughout the entire hearing petitioner and his wife
relentlessly pursued frivolous and groundless tax protester
arguments without allowing Mr. Dolin the opportunity to discuss
any collection alternatives. As a result, Mr. Dolin ended the
hearing. Petitioner also testified that he did not seek
collection alternatives.
Section 6330(c)(2)(A) permits a taxpayer to challenge the
appropriateness of the intended method of collection, offer
alternatives to collection, or raise a spousal defense to
collection. A settlement officer is not required to prolong a
face-to-face meeting to entertain frivolous, meritless, or
groundless arguments. See sec. 6330(c)(2)(A); Holliday v.
Commissioner, T.C. Memo. 2005-240; Kolker v. Commissioner, T.C.
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