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asked petitioner whether he wished to testify, to call witnesses,
or to introduce any other evidence. Petitioner declined to do
any of these things. After the trial, petitioner filed a brief
in which he admitted that he had not been prepared to introduce
any new matters at the hearing, and he persisted with his vague
assertion that this case involves “erroneous dates of assessment
and amounts unjustifiably entered.”
In the light of the above and considering petitioner’s
frivolous assertions and arguments, a further hearing in this
case (recorded or not) would not have been, nor would it be,
productive. See Lunsford v. Commissioner, 117 T.C. 183, 189
(2001); Bean v. Commissioner, T.C. Memo. 2006-88. Moreover,
under the circumstances, petitioner has given us no reason to
believe that remanding this matter to the Appeals Office would in
any way advance the policies underlying section 6330. Thus, we
conclude that a remand is unwarranted.
The record reflects that the Appeals Office properly
verified that all applicable laws and administrative procedures
governing the assessment and collection of petitioner’s unpaid
tax liabilities were met. On the basis of this record, we
conclude as a matter of law that respondent did not abuse his
discretion. Respondent’s determination that the filing of a
notice of Federal tax lien was appropriate is sustained.
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay the United States a penalty in an amount not to
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