- 21 - telephone by Settlement Officer Gwenda Dumas". Nonetheless, even if we assume, without deciding, that Mr. Gukich participated in the conduct of petitioner's hearing, it would not be grounds for a remand in this case, because the arguments that petitioner has raised against the collection action are all frivolous and groundless. Thus, we conclude that, even if Mr. Gukich's apparently supervisory role in issuing the notice of determination were considered "conduct" of the hearing for purposes of section 6330(b)(3), such participation by Mr. Gukich could not have affected the outcome of the section 6330 hearing and was therefore harmless error. IV. Conclusion Petitioner raised no other issues. Because we find that the Appeals employees' refusal to allow petitioner to challenge the underlying tax liability and Mr. Gukich's possible participation in the conduct of the hearing after prior involvement would constitute harmless error, we conclude that neither requires that this case be remanded to Appeals for a further hearing; it would not be "necessary or productive" to do so. See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001). Instead, we shallPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007