Robert Lee, Jr. - Page 7

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          legitimate claim for relief.                                                
               Considering all the facts and circumstances, we agree with             
          respondent that the Appeals officer’s decision to preclude                  
          petitioner from making an audio recording of the administrative             
          hearing was at most harmless error.  Moreover, petitioner has               
          given us no reason to believe that remanding this matter to                 
          respondent’s Appeals Office would be productive or otherwise                
          advance the policies underlying section 6330.  Consistent with              
          our reasoning in Kemper v. Commissioner, supra, we conclude that            
          a remand is unwarranted.6                                                   
               The Form 4340 attached to respondent’s motion in this case             
          shows that respondent properly assessed the tax liability that              
          respondent intends to collect and respondent properly notified              
          petitioner of the assessment by way of a notice of balance due.             
          See, e.g., Hughes v. United States, 953 F.2d 531, 536 (9th Cir.             
               Numerous cases establish that no particular form of                    
          verification of an assessment is required, that no particular               
          document need be provided to a taxpayer at an administrative                
          hearing conducted under section 6330, and that a Form 4340 (such            
          as that included in this record) and other transcripts of account           

               6As previously discussed, petitioner was given every                   
          opportunity to file a proper amended petition setting forth a               
          valid claim for relief.  However, petitioner failed to comply               
          with the Court’s Order to file an amended petition.                         

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