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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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Last modified: May 25, 2011