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that we have found to be frivolous and/or groundless.
We turn now to petitioners’ argument under section
7521(a)(1) that the refusal by the Appeals Office to permit
petitioners to make an audio recording of the Appeals Office
hearing that the settlement officer scheduled on November 27,
2002, was improper. Before they filed the petition in this case,
petitioners made statements and requests and advanced contentions
and arguments that the Court has found to be frivolous and/or
groundless. In the petition and the attachments thereto, peti-
tioners persisted in advancing such frivolous and/or groundless
statements, contentions, arguments, and requests. Consequently,
even though we held in Keene v. Commissioner, 121 T.C. 8, 19
(2003), that section 7521(a)(1) requires the Appeals Office to
allow a taxpayer to make an audio recording of an Appeals Office
hearing under section 6330(b), we conclude that (1) it is not
necessary and will not be productive to remand this case to the
Appeals Office for a hearing under section 6320(b) in order to
allow petitioners to make such an audio recording, see Lunsford
v. Commissioner, 117 T.C. 183, 189 (2001), and (2) it is not
necessary or appropriate to reject respondent’s determinations to
proceed with the collection action as determined in the notice of
determination with respect to petitioners’ respective unpaid
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