- 36 - In the Court’s May 29, 2003 Order, we found that petitioners’ petition and certain exhibits attached thereto contained statements, contentions, arguments, and questions that were frivolous and/or groundless. We conclude that the following allegations in petitioners’ petition raise valid issues that we shall address: Petitioners’ allegation that the Appeals Office improperly refused to allow them to make an audio recording of their Appeals Office hearing, as required by section 7521(a)(1), and petitioners’ allegation that petitioners’ unpaid liability for 1996 and petitioners’ unpaid liability for 1997 were discharged in petitioners’ bankruptcy proceeding. We consider first petitioners’ position that the refusal by the Appeals Office to permit them to make an audio recording of the Appeals Office hearing held on November 20, 2002, was improper under section 7521(a)(1). Throughout the period commencing with petitioners’ sending to the IRS their 1996 Form 1040 reporting total income of $0 and total tax of $0 and ending with their filing briefs with the Court, petitioners have made statements, contentions, arguments, and requests and raised questions that the Court finds to be frivolous and/or groundless. Consequently, even though we held in Keene v. Commissioner, 121 T.C. 8 (2003), that section 7521(a)(1) requires the Appeals 3(...continued) frivolous and/or groundless.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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