- 3 - 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 factPage: Previous 1 2 3 4 5 NextLast modified: November 10, 2007