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audio recording of a section 6330 hearing. Keene v.
Commissioner, 121 T.C. 8, 16, 19 (2003). However, it is not
necessary or productive to remand this case to respondent’s
Appeals Office merely to provide the petitioner a recorded
hearing where he previously attended and participated in a
section 6330 hearing. Id. at 19; Durrenberger v. Commissioner,
T.C. Memo. 2004-44; Kemper v. Commissioner, T.C. Memo. 2003-195;
see also Lunsford v. Commissioner, supra at 189.
In the present case, petitioner participated in his section
6330 hearing. In addition, we note that petitioner has only
advanced contentions, arguments, and questions that the Court
finds to be frivolous. Remanding this case to Appeals, and thus
allowing petitioner to continue to advance the same frivolous
arguments, would not be productive. For these reasons, we
conclude that any error made by respondent in not allowing
petitioner to record the hearing was harmless. See Kemper v.
Commissioner, supra.
Petitioner also argues that respondent erred in rejecting
petitioner’s proposed collection alternative. Petitioner
testified, and the notice of determination reflects, that he
offered to pay his outstanding tax liability in full at his
section 6330 hearing “if [respondent] can show me which Internal
Revenue Code section makes me liable.” This Court has found such
an argument to be frivolous. Rowlee v. Commissioner, 80 T.C.
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