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Commissioner, T.C. Memo. 2003-196; Kemper v. Commissioner, T.C.
Memo. 2003-195. 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.
The Court concludes that all pertinent issues relating to the
propriety of the collection determination can be decided through
review of the materials before it.
2. Review of Underlying Liabilities
A statutory notice of deficiency for 1999 was issued to
petitioner, and communications from petitioner reference the
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