Brad L. Barnhill - Page 8
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Commissioner, 117 T.C. 159 (2002). As already explained, the
hearing before Appeals is intended to be informal.
In addition, a recent regulation provides that “The formal
hearing procedures required under the Administrative Procedure
Act, 5 U.S.C. sec. 551, et. seq. do not apply to * * * [section
6330 hearings]”. Sec. 301.6330-1(d), A-D6, Proced. & Admin.
Regs. This regulation also provides that a face-to-face
interview is not required at a section 6330 hearing and that a
taxpayer does not have the right to subpoena and examine
witnesses. Sec. 301.6330-1(d), Proced. & Admin. Regs.
Accordingly, we hold that respondent did not abuse his discretion
in determining to proceed with the proposed collection action in
Petitioner set forth other contentions on brief and at
trial. To the extent not herein discussed, petitioner’s
contentions have been rendered moot by our holding or are without
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011