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placed at issue, the Court will review the matter on a de novo
basis. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). Although petitioners
did not receive a notice of deficiency with respect to their
taxable years 1997 and 1998, the Court finds the contentions and
arguments which petitioners advanced in their petition and which
challenge the existence or the amount of petitioners’ unpaid
liabilities for 1997 and 1998 to be frivolous and/or groundless.
We now turn to the remaining issues that petitioners raised
at their Appeals Office hearing and in the petition with respect
to petitioners’ notices of determination, which we shall
review for abuse of discretion. Sego v. Commissioner, supra;
Goza v. Commissioner, supra. As was true of petitioners’ attach-
ment to Form 12153, petitioners’ explanation for their amended
1997 joint return, and petitioners’ explanation for their amended
1998 joint return, petitioners’ petition, except for a possible
argument under section 7521(a)(1), contains statements, conten-
tions, arguments, and requests that the Court finds to be frivo-
lous and/or groundless.
We turn to petitioners’ possible argument under section
7521(a)(1) that the refusal by the Appeals Office to permit
petitioners to continue to make an audio recording of the Appeals
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