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the legislative history to sections 6320 and 6330 does not
address this issue. See H. Conf. Rept. 105-599, at 263-267
(1998).
Respondent asserts that for petitioner’s geographic
location, Appeals hearings are generally held at the Appeals
Office in Sunrise, Florida. Petitioner does not dispute this
claim. From petitioner’s correspondence with the Appeals
officer, we assume that petitioner’s complaint is that under
section 6320(b) he is entitled to an Appeals hearing in West Palm
Beach, Florida, the location of his alleged witnesses and the
place of his residence.
Because Congress has not specifically addressed the location
for an Appeals hearing, we look to other tax contexts for
guidance. In the examination context, Congress has stated that
the time and place of an examination shall be such time and place
as “may be fixed by the Secretary and as are reasonable under the
circumstances.” Sec. 7605(a). Under section 301.7605-1(d)(2),
Proced. & Admin. Regs., the location of an office examination is
based on the taxpayer's residence:
(d) Place of examination–- * * *.
* * * * * * *
(2) Office examinations–-(i) In general. * * *
An office examination generally will take place at the
closest Service office within the district encompassing
the taxpayer’s residence * * *. It generally is not
reasonable for the Service to require a taxpayer to
attend an examination at an office within an assigned
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