Taylor v. Commissioner

MEMORANDUM **

Sue Taylor appeals pro se the Tax Court’s summary judgment in favor of the Commissioner of Internal Revenue (“Commissioner”) in her action contesting deficiencies for tax year 1997. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo, see Talley Indus. Inc. v. Comm’r, 116 F.3d 382, 385 (9th Cir.1997), and we affirm.

Taylor’s sole contention on appeal is that she is entitled to a second collection due process hearing so that she may record the hearing. Recording the collection due process hearing is permitted upon advance request, but Taylor made no such request,…