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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,
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