That’s what Judge Kashi (“My or the High”) Way tells Tisha S. Hillman, T. C. Memo. 2025-84, filed 8/6/25. She wants to fight over the amounts she self-reported, and didn’t file amended returns when she was offered the chance by the AO at her CDP.

Tisha wants a hearing before IRS filed a NFTL. That’s a nonstarter.

“… it is important to note that the Code does not even afford a taxpayer a right to a CDP hearing to contest an NFTL until after the government has in fact filed the NFTL. See § 6320(a) (describing the manner in which a taxpayer is notified of an NFTL filing under section 6323 and the period during which that taxpayer may request a CDP hearing). This is in contrast to requesting a CDP hearing to contest a levy under section 6330, which explicitly forbids the IRS from levying on a taxpayer’s property before notifying the taxpayer in writing of the right to a CDP hearing and permitting the hearing to occur. § 6330(a)(1). Thus, petitioner’s argument that her CDP rights were violated because an NFTL was filed before she had a hearing is without merit.” T. C. Memo. 2025-84, at p. 8.

But wait, there’s more!

Judge Way blows off “… petitioner’s argument concerning the application of the Thirteenth Amendment and her demand for the Court to order $48 million in sanctions against respondent. Petitioner, who the record indicates has a legal education, is warned that the Court is authorized under section 6673(a)(1) to impose a penalty not exceeding $25,000 whenever a taxpayer’s position in a proceeding is frivolous or groundless. Petitioner is therefore cautioned that a penalty may be imposed in any future case before this Court should she continue to pursue frivolous positions. The Court declines to impose sanctions against respondent.” T. C. Memo. 2025-84, at pp. 9-10, footnote 4.

Note that Ms. Hillman is a SuperLawyer.