- 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011