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Stated otherwise, cases will not be remanded to Appeals, nor
determinations otherwise invalidated, merely on account of the
lack of a recording when to do so is not necessary and would not
be productive. See, e.g., Frey v. Commissioner, supra;
Durrenberger v. Commissioner, supra; Brashear v. Commissioner,
supra; Kemper v. Commissioner, supra; see also Lunsford v.
Commissioner, 117 T.C. 183, 189 (2001).
A principal scenario falling short of the necessary or
productive standard exists where the taxpayers rely on frivolous
or groundless arguments consistently rejected by this and other
courts. See, e.g., Frey v. Commissioner, supra; Brashear v.
Commissioner, supra; Kemper v. Commissioner, supra. Here,
because the contentions advanced by petitioner throughout the
administrative process and before the Court are of this nature,
and because petitioner in fact received an in-person conference,
this case is closely analogous to those just cited. The record
does not indicate that any purpose would be served by remand. We
conclude that all pertinent issues relating to the propriety of
the collection determination can be decided through review of the
materials before us.
2. Review of Underlying Liabilities
Statutory notices of deficiency for 1993, 1994, 1995, 1996,
and 1997 were issued to petitioner. Petitioner has at no time
alleged that he did not receive these notices, and the record
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