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such as spousal defenses or collection alternatives, but he chose
not to do so. Instead, petitioner stated that his position was
summarized in his request for a hearing, which is part of the
record and contains five pages of frivolous and groundless
arguments. Petitioner’s posttrial brief also fails to raise any
relevant issues. Consequently, even though we held in Keene that
section 7521(a)(1) requires the Appeals Office to allow a
taxpayer to make an audio recording of a hearing, we conclude
that it is not necessary and would not be productive to remand
this case to the Appeals Office for another hearing in order to
allow petitioner to make such an audio recording. See Lunsford
v. Commissioner, 117 T.C. 183, 189 (2001). The record is
sufficient for us to address petitioner’s arguments without an
additional hearing.
Petitioner admits that he received the notice of deficiency
issued to him for 1997 but claims that the notice of deficiency
is invalid because it was not signed by the Secretary of the
Treasury himself or his delegate. We reject petitioner’s
contention. The Secretary’s authority to issue notices of
deficiency was delegated to the Service Center Directors.
Delegation Order No. 77 (Rev. 28), effective May 17, 1996; secs.
301.6212-1(a), 301.7701-9(b), Proced. & Admin. Regs.; see also
Nestor v. Commissioner, 118 T.C. 162, 165 (2002). The notice of
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