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materials (January 2006 letter). In the January 2006 letter,
Settlement Officer Feist: (1) Informed petitioner that the
arguments he advanced were frivolous, groundless, or arguments
that Appeals Office employees may not consider; (2) requested
petitioner submit relevant, nonfrivolous information (such as
petitioner’s signed tax returns for 1992 and 1993, challenges to
the appropriateness of collection actions, or proposals of
collection alternatives); (3) scheduled a phone conference with
petitioner for February 9, 2006; and (4) attached a copy of an
IRS document entitled “The Truth About Frivolous Tax Arguments”,
which detailed several of the frivolous and groundless arguments
that petitioner asserted in the materials he sent to respondent.
On January 25, 2006, and numerous other dates, petitioner
sent to respondent additional materials containing frivolous and
groundless arguments, questions, and statements (additional
frivolous materials). Settlement Officer Feist responded to
petitioner’s additional frivolous materials and requested
petitioner submit relevant, nonfrivolous information regarding
the years in issue. Settlement Officer Feist: (1) Informed
petitioner, again, that the arguments he advanced were frivolous,
groundless, or arguments that Appeals Office employees may not
consider; (2) advised petitioner to contact him by February 7,
2006, if petitioner wished to submit relevant, nonfrivolous
information for Settlement Officer Feist’s consideration or to
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Last modified: November 10, 2007