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Whether petitioner is entitled to a new Appeals Office hearing
because he was not permitted to make an audio or stenographic
recording of his hearing; and (2) whether respondent’s
determination to sustain the notice of intent to levy and the
notice of Federal tax lien filing for petitioner’s unpaid 1997
tax liability was an abuse of discretion. Because petitioner has
not raised any relevant issues relating to the unpaid tax
liability, we hold that a new hearing is not necessary and
respondent’s determination to proceed with collection was not an
abuse of discretion.
FINDINGS OF FACT
On April 30, 1998, petitioner filed his 1997 Federal income
tax return. On the 1997 return, petitioner reported his total
income as zero and his total tax due as zero. The return claimed
a refund of $1,086.82. On May 12, 2000, respondent issued a
notice of deficiency to petitioner determining a deficiency of
$6,023 and additions to tax under sections 6651(a)(1)1 and
6654(a) of $1,493 (the 1997 liability). On May 13, 2000,
petitioner sent a letter to respondent asserting various
frivolous and groundless arguments challenging respondent’s
determination and the validity of the notice of deficiency.
Petitioner did not petition this Court with respect to the notice
1Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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