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6330(c)(2)(B). Thus, petitioner may not challenge his underlying
tax liability for 1998.
6. Whether Petitioner Is Liable for Tax for 2001 and 2002
in the Amounts Respondent Contends
Respondent does not contend, and the record does not show,
that petitioner received a notice of deficiency for 2001 or 2002.
Thus, petitioner may dispute respondent’s conclusions regarding
his tax liabilities for those years. Id. At trial, petitioner
testified that the issues he would have raised at a face-to-face
hearing are the issues that he described in his letters to
respondent and in the petition. We conclude that petitioner is
liable for the taxes that were the subject of the Federal tax
lien for 2001 and 2002.
7. Whether To Remand This Case to Appeals for a Face-to-
Face Hearing
Petitioner cites Treasury regulations which state that if a
taxpayer wants a face-to-face hearing, the taxpayer must be
offered an opportunity for a hearing at the Appeals Office
closest to the taxpayer’s residence. Sec. 301.6320-1(d)(2),
Q&A-D7, Proced. & Admin. Regs. Petitioner contends he was
entitled to have a face-to-face hearing. We disagree.
In Lunsford v. Commissioner, 117 T.C. 183, 189 (2001), the
Court declined to remand the case to the Appeals Office for a
hearing because the taxpayer could not prevail on any of the
issues he had raised in the proceeding. We held that it was
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