Bharat S. Parikh - Page 4

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          has not identified what, if any, penalties he wants us to                   
          consider.  Therefore, regardless of whether petitioner was                  
          accorded his right to a hearing pursuant to section 6330(b), he             
          has not been prejudiced, and it is neither necessary nor                    
          productive to remand this case to the Appeals Office to consider            
          petitioner’s contentions.  See Nestor v. Commissioner, 118 T.C.             
          162, 167 (2002); Lunsford v. Commissioner 117 T.C. 183, 189                 
          (2001).  Respondent’s determinations are sustained.                         
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          























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