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filed Notice of Federal Tax Lien. This determination
was made because the taxpayers failed to raise any
relevant issue, offer a collection alternative, or
present any reason to justify withdrawal. Therefore,
the determination by Appeals balances the need for
efficient collection of taxes with the taxpayer’s
legitimate concern that any collection action be no
more in [sic] intrusive than necessary.
In response to the notice of determination, petitioners
filed with the Court a petition with attachments that we consider
to be part of the petition. Except for an argument under section
7521(a)(1), the petition and the attachments thereto contained
statements, contentions, arguments, and requests that the Court
finds to be frivolous and/or groundless.5 With respect to sec-
tion 7521(a)(1), petitioners alleged that the Appeals Office
refused to allow them to make an audio recording of the Appeals
Office hearing that the settlement officer had scheduled on
November 27, 2002, and that that refusal was improper under that
section.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
5The frivolous and/or groundless statements, contentions,
arguments, and requests in petitioners’ petition and the attach-
ments to that petition are very similar to the frivolous and/or
groundless statements, contentions, arguments, and requests in
the respective petitions filed with the Court by certain other
taxpayers. See, e.g., Guerrier v. Commissioner, T.C. Memo. 2002-
3.
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