Randy S. Quigley - Page 14

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               On the record before us, we shall grant respondent’s motion.            
               To reflect the foregoing,                                               

                                              An order granting respondent’s           
                                        motion and decision for respondent             
                                        will be entered.                               






















               10(...continued)                                                        
          cuss.”  Petitioner did not respond to that letter.  Even if                  
          respondent’s Appeals officer had not offered petitioner an                   
          Appeals Office hearing, on the instant record we would hold that             
          (1) it is not necessary and will not be productive to remand this            
          case to the Appeals Office for a hearing under sec. 6330(b), see             
          Lunsford v. Commissioner, 117 T.C. 183, 189 (2001), and (2) it is            
          not necessary or appropriate to reject respondent’s determination            
          to proceed with the collection action as determined in the notice            
          of determination with respect to petitioner’s unpaid liability               
          for 1999, see id.                                                            





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