Ronald Lee Snyder - Page 14

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          At the hearing held by the Appeals Office, petitioner did not               
          raise any relevant issues challenging the appropriateness of the            
          notice of tax lien or the notice of intent to levy relating to              
          his taxable years 1994, 1996, 1998, and 1999.  In the notice of             
          determination and the decision letter, the Appeals Office con-              
          cluded that the petitioner advanced only frivolous arguments at             
          that hearing.  Petitioner does not claim here that the amount of            
          tax reported in his return for each of his taxable years 1994 and           
          1996 is not correct.  Instead, he advances statements, conten-              
          tions, arguments, and requests in his petition and the supplement           
          to that petition that we have found to be frivolous and/or                  
          groundless.                                                                 
               With respect to petitioner’s taxable years 1998 and 1999,              
          respondent issued, and petitioner received, a notice of defi-               
          ciency for those years, but he did not file a petition with                 
          respect to that notice.  On the instant record, we find that                
          petitioner may not challenge the existence or the amounts of                
          petitioner’s respective unpaid liabilities for 1998 and 1999.               
               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 the hearing held by that           
          office on January 16, 2001, was improper.8  Before he filed the             

               8We note that the record does not establish that petitioner            
          complied with the requirement of sec. 7521(a)(1) that he present            
                                                             (continued...)           




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