- 11 - by Appeals indicate that Congress contemplated the type of informal administrative Appeals hearing that has been historically conducted by Appeals and prescribed by section 601.106(c), Statement of Procedural Rules. The nature of the administrative Appeals process does not include the taking of testimony under oath or the compulsory attendance of witnesses. We therefore hold that a hearing before Appeals pursuant to section 6330 does not include the right to subpoena witnesses. Section 6065 Issue Finally, petitioner alleges that the notice of determination was not signed in accordance with the requirements of section 6065. Section 6065 provides: SEC. 6065. VERIFICATION OF RETURNS. Except as otherwise provided by the Secretary, any return, declaration, statement, or other document required to be made under any provision of the internal revenue laws or regulations shall contain or be verified by a written declaration that it is made under the penalties of perjury. Section 6065 requires returns to contain or be verified by a written declaration that they are made under the penalties of perjury. To facilitate a taxpayer’s compliance with this requirement, for example, Form 1040, Individual Income Tax Return, contains a preprinted jurat.5 By signing the jurat 5The jurat is the portion of the Form 1040 which reads: (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011