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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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