Ronald A. Davis - Page 11




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          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...)           





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