Robert E. Crandall - Page 15

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          warrant further consideration of the merits of his case by the              
          Appeals Office or this Court.  Petitioner, however, merely                  
          continued to focus on the denial of a recorded hearing and                  
          offered no substantive issues of merit.                                     
               Hence, despite repeated warnings and opportunities, the only           
          contentions other than the recorded hearing advanced by                     
          petitioner are, as will be further discussed below, of a nature             
          previously rejected by this and other courts.  The record                   
          therefore does not indicate that any purpose would be served by             
          remand or additional proceedings.  The Court concludes that all             
          pertinent issues relating to the propriety of the collection                
          determination can be decided through review of the materials                
          before it.                                                                  
                    2.  Review of Underlying Liabilities                              
               With respect to 1999, a statutory notice of deficiency was             
          issued to petitioner, and he has at no time alleged that he did             
          not receive the notice.  He did not timely petition this Court              
          for redetermination when he had the opportunity to do so.                   
          Accordingly, petitioner is precluded under section 6330(c)(2)(B)            
          from disputing his underlying liability for 1999 in this                    
               With respect to 1998, because the assessments were based on            
          petitioner’s filed return, no notice of deficiency was issued.              
          However, to the extent that petitioner might be entitled to                 

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