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them to be without merit and/or irrelevant.10
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and decision will be entered
for respondent.
10We note that in petitioner’s response petitioner contends
that “the law (26USC 7521) [sic] clearly provides that Petitioner
had a right to tape the CDP hearing at issue” and that he “is
entitled to a summary judgment just on the ground that he was
denied the right to make a tape recording & a stenographic
recording.” We shall not address petitioner’s contention. That
is because, assuming arguendo that sec. 7521(a)(1) were applica-
ble in the case of an Appeals Office hearing under sec.
6320(b)(1) and/or sec. 6330(b)(1), the record does not establish
that petitioner complied with the requirement of sec. 7521(a)(1)
that he present respondent with his request to make an audio
recording of his Appeals Office hearing in advance of that
hearing.
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