- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011