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request a letter containing frivolous and groundless arguments.
Petitioner did not propose any collection alternatives.
On April 11, 2005, Appeals Account Resolution Specialist
Sophie Tittle sent petitioner a letter advising him that the
issues he raised were frivolous or were issues that the Appeals
Office does not consider. Ms. Tittle scheduled a telephone
conference for May 10, 2005. Ms. Tittle reviewed petitioner’s
administrative file for 1989, 1990, and 1998 and confirmed that
respondent had complied with all applicable laws and
administrative procedures. On May 10, 2005, Settlement Officer
Lupe Silva called petitioner at the telephone number listed on
petitioner’s hearing request; however, the phone number no longer
was in service.
Respondent issued petitioner a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
regarding his 1989, 1990, and 1998 tax years. In the notice of
determination, respondent sustained the proposed collection
action.
Discussion
I. Motion for Summary Judgment
Rule 121(a) provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
Full or partial summary judgment may be granted only if it is
demonstrated that no genuine issue exists as to any material fact
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Last modified: November 10, 2007