Terri Armstrong - Page 10




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          year 1992 or taxable year 1995.                                             
                                       OPINION                                        
               Where, as is the case here, the validity of the underlying             
          tax liability is not placed at issue, the Court will review the             
          administrative determination of the IRS Appeals Office for abuse            
          of discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000);             
          Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).                         
               In petitioner’s opening brief, petitioner asks us to con-              
          sider the following issues:  (1) Whether “petitioner was entitled           
          to an in person hearing” and (2) whether “the Individual Master             
          File Transcripts[6] * * * [and] Certificates of Assessments and             
          Payments were admissible in evidence?”7                                     
               We turn first to the evidentiary issues that petitioner                


               6As discussed below, petitioner objects to the admissibility           
          into evidence of, inter alia, certain documents that she refers             
          to as the “Individual Master File Transcripts” (IMF transcripts).           
          We assume that petitioner is referring to the documents entitled            
          “Internal Revenue Service transcript(s)” (IRS transcripts) that             
          were part of a joint exhibit that the parties attached to, and              
          incorporated into, the stipulation of facts that they offered               
          into evidence at the beginning of the trial in this case.  The              
          Court admitted into evidence and made part of the record in this            
          case the stipulation of facts together with the exhibits attached           
          thereto.  Consistent with the parties’ stipulation of facts in              
          the instant case, we shall refer to those transcripts as IRS                
          transcripts.                                                                
               7Petitioner raises no other issues on brief.  We conclude              
          that petitioner has abandoned any other issues that she raised in           
          the petition and at trial.  See Rybak v. Commissioner, 91 T.C.              
          524, 566 n.19 (1988).  Assuming arguendo that we had not con-               
          cluded that petitioner abandoned any other issues that she raised           
          in the petition and at trial, on the record before us, we find no           
          merit in such other issues.                                                 




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