- 11 - a result, we held that it was neither necessary nor productive to remand the case to the Appeals Office. Id.; see Kemper v. Commissioner, T.C. Memo. 2003-195 (remand to record face-to-face hearing denied); see also Keene v. Commissioner, 121 T.C. 8, 19- 20 (2003). The same reasoning applies here because petitioner is liable for the underlying income tax and all of his other arguments are frivolous. C. Conclusion We conclude that respondent’s determination not to withdraw the notice of Federal tax lien was not an abuse of discretion. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011