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moot, in that this case was remanded to Appeals subsequent to the
petition's filing, at respondent's request, for the purpose of
affording petitioner a hearing, and the resulting 2004
supplemental determination contained the verification, no prior
involvement, and balancing findings required by section
6330(b)(3), (c)(3)(A) and (C). Nonetheless, in his statement
offered at trial petitioner persists in arguing that respondent's
issuance of the initial notice of determination was an abuse of
discretion entitling petitioner to a decision in his favor. As
petitioner puts it, respondent's position in this case amounts to
a cry of "Mulligan!" and seeks an "impermissible 'do over'".
We disagree. In appropriate circumstances we may remand a
case to the Appeals office to provide a hearing under section
6330(b). See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001);
Butti v. Commissioner, T.C. Memo. 2006-66; Harrell v.
Commissioner, T.C. Memo. 2003-271. Since, as more fully
discussed below, petitioner has been accorded all prelevy rights
to which he is entitled under section 6330, his effort to exploit
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