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            
          this case.                                                                  
               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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