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T.C. 176, 181-182 (2000).
Where, as is the case here, the validity of the underlying
tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of the Internal
Revenue for abuse of discretion. Sego v. Commissioner, supra at
610; Goza v. Commissioner, supra at 182.
We turn now to petitioner’s argument under section
7521(a)(1) that the refusal by the Appeals Office to permit
petitioner to make an audio recording of any Appeals Office
hearing was improper. Before she filed the petition in this
case, petitioner made statements and requests and advanced
contentions and arguments that the Court has found to be frivo-
lous and/or groundless. In the petition and the attachments
thereto, petitioner 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 sections 6320(b)
and 6330(b) in order to allow petitioner 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
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