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hearing. Sec. 7521(a)(1). In situations where an administrative
hearing took place prior to our opinion in Keene v. Commissioner,
supra, we remand a case to the Appeals Office for further review
only if it is necessary and productive to do so. Keene v.
Commissioner, supra at 19; Frey v. Commissioner, T.C. Memo. 2004-
87; Durrenberger v. Commissioner, T.C. Memo. 2004-44; Brashear v.
Commissioner, T.C. Memo. 2003-196; Kemper v. Commissioner, T.C.
Memo. 2003-195. We have consistently held that a taxpayer’s
reliance on frivolous or groundless arguments falls short of the
necessary or productive standard for remand. See, e.g., Johnston
v. Commissioner, T.C. Memo. 2004-224; Frey v. Commissioner,
supra; Kemper v. Commissioner, supra.
The administrative record in the present case indicates that
although petitioner was provided with an opportunity to discuss
relevant issues relating to the collection of her unpaid tax
liability, she declined to do so. She did not propose any
collection alternatives or challenge the appropriateness of the
proposed levy, and she continued to advance frivolous and
groundless arguments about the Federal income tax system.
At no point in her dealings with respondent’s Appeals Office
or with this Court did petitioner raise any legitimate issue
involving the collection of her tax liability. The record in
this case shows that no necessary or productive purpose would be
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