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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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