- 14 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011