- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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