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bankruptcy discharge of the 1991 liabilities or their
payment--have been considered in this proceeding and found to
lack merit. Thus, regardless of whether petitioners were
initially accorded their right to a hearing under section
6330(b), they have not been prejudiced, and we do not believe it
is “either necessary or productive” to remand this case for a
hearing on the claims we have found legally insufficient to
forestall collection. See Lunsford v. Commissioner, 117 T.C.
183, 189 (2001); Moore v. Commissioner, T.C. Memo. 2003-1.
Conclusion
Petitioners have not raised any spousal defenses, other
challenges to the appropriateness of the collection action, or
collection alternatives. We have considered every contention
raised by petitioners, and conclude that each is without merit.
We therefore hold that respondent may proceed with the proposed
collection action. To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011