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neither necessary nor productive to remand the case to the
Appeals Office. Id.; see Kemper v. Commissioner, T.C. Memo.
2003-195 (remand to record face-to-face hearing denied); see also
Keene v. Commissioner, 121 T.C. 8, 19-20 (2003). The same
reasoning applies here because petitioner is liable for the
underlying income tax and his other arguments are frivolous.
During trial, petitioner was given the opportunity to raise
the arguments that he would have made at a face-to-face hearing.
Petitioner stated that the issues that he would have raised were
included in his letters to respondent and in the petition.
During the trial, petitioner stated that his only arguments for
overturning respondent’s determination, other than seeking a
face-to-face hearing, were included in his correspondence to
respondent and in the petition. Those arguments were frivolous.
Thus, it is neither necessary nor productive to remand the case
to the Appeals Office.
8. Conclusion
We sustain respondent’s determination to proceed with
collection of income taxes, additions to tax, and penalties other
than those under sections 6682 and 6702, and interest by lien
from petitioner for 1998, 2001, and 2002.
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