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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.
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