Kevin Thompson - Page 2

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          Whether petitioner is entitled to a new Appeals Office hearing              
          because he was not permitted to make an audio or stenographic               
          recording of his hearing; and (2) whether respondent’s                      
          determination to sustain the notice of intent to levy and the               
          notice of Federal tax lien filing for petitioner’s unpaid 1997              
          tax liability was an abuse of discretion.  Because petitioner has           
          not raised any relevant issues relating to the unpaid tax                   
          liability, we hold that a new hearing is not necessary and                  
          respondent’s determination to proceed with collection was not an            
          abuse of discretion.                                                        
                                  FINDINGS OF FACT                                    
               On April 30, 1998, petitioner filed his 1997 Federal income            
          tax return.  On the 1997 return, petitioner reported his total              
          income as zero and his total tax due as zero.  The return claimed           
          a refund of $1,086.82.  On May 12, 2000, respondent issued a                
          notice of deficiency to petitioner determining a deficiency of              
          $6,023 and additions to tax under sections 6651(a)(1)1 and                  
          6654(a) of $1,493 (the 1997 liability).  On May 13, 2000,                   
          petitioner sent a letter to respondent asserting various                    
          frivolous and groundless arguments challenging respondent’s                 
          determination and the validity of the notice of deficiency.                 
          Petitioner did not petition this Court with respect to the notice           

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code as amended.                                       

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