- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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