- 8 -
petitioner’s name, the date of assessment, the character of the
liability assessed (“Form 1040”), the taxable periods, and the
amounts assessed. This information satisfied the requirements of
section 6203 and section 301.6203-1, Proced. & Admin. Regs. See
Balice v. Commissioner, T.C. Memo. 2005-161 n.6.
Petitioner complains that he was not given a face-to-face
hearing. Petitioner’s complaint is without merit. A face-to-
face hearing is not invariably required by section 6330; the
hearing may be conducted by correspondence or telephone. See
Katz v. Commissioner, 115 T.C. 329, 337-338 (2000); Summers v.
Commissioner, T.C. Memo. 2006-219. Petitioner was offered a
face-to-face hearing to consider legitimate issues. Petitioner
chose to pursue only frivolous and groundless arguments as
asserted in his Form 12153 and in correspondence with the Appeals
officer. In these circumstances, the Appeals officer did not
abuse her discretion in determining that a face-to-face hearing
would not be productive to consider petitioner’s arguments. See,
e.g., Summers v. Commissioner, supra. Moreover, in this
proceeding, petitioner has raised no legitimate issue that would
suggest that it would be productive or appropriate to remand this
case to the Office of Appeals for further proceedings. See
Lunsford v. Commissioner, 117 T.C. 183, 189 (2001).
Petitioner has made various other arguments and requests
that the Court finds frivolous or groundless. We conclude that
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011