Mary K. Dues - Page 8

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          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.                     
               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-           

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