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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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Last modified: May 25, 2011