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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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