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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.
1992).
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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