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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.
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.
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