- 8 - 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), petitioner alleged that the refusal by the Appeals Office to allow her to make an audio recording of any Appeals Office hearing 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, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We conclude that there are no genuine issues of material fact regarding the questions raised in respondent’s motion. Respondent issued a notice of deficiency to petitioner with respect to taxable years 1997 and 1998, but petitioner did not file a petition with the Court with respect to that notice. On the instant record, we find that petitioner may not challenge the existence or the amount of petitioner’s respective unpaid liabil- ities for 1997 and 1998. Sec. 6330(c)(2)(B); Sego v. Commis- sioner, 114 T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 5The frivolous and/or groundless statements, contentions, arguments, and requests in petitioner’s petition and the attach- ments to that petition are 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., Copeland v. Commissioner, T.C. Memo. 2003- 46.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011