- 10 - require the IRS to collect unpaid amounts from her rather than from him. Cf. Baranowicz v. Commissioner, 432 F.3d 972 (9th Cir. 2005); Kovitch v. Commissioner, 128 T.C. 108 (2007); Maier v. Commissioner, 119 T.C. 267 (2002), affd. 360 F.3d 361 (2d Cir. 2004); Miller v. Commissioner, 115 T.C. 582, 586-588 (2000), affd. 21 Fed. Appx. 160 (4th Cir. 2001). Petitioner contends that the failure to record the hearing and the failure to have certain documents in the form of admissible evidence make the determination “null, void, and unenforceable”; that the assignment of his hearing to a Settlement Officer rather than an Appeals Officer and the issuance of the notice of determination signed by an Appeals Team Manager were denials of due process and render the notice “unenforceable”; and that certain IRS employees were not competent to take the steps reflected in the administrative record. Although petitioner had the option, under section 7521, to request in advance that the hearing be recorded, he has stipulated that he did not make such a request. Despite his rhetoric, petitioner has not shown any requirement of law that was not followed by the persons involved. He has not acknowledged or distinguished law contrary to his contentions. See, e.g., Living Care Alternatives of Utica, Inc. v. United States, 411 F.3d 621, 624 (6th Cir. 2005); Cox v. Commissioner,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007