- 9 - 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 rejectPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011