Kevin Thompson - Page 7

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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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