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undue inconvenience to the taxpayer.[10]
The Treasury regulations in the examination context consider
the distances taxpayers will have to travel to submit information
to the IRS and attempt to provide taxpayers with venues at IRS
offices near their homes. At the same time, the Treasury
regulations recognize the limited resources of the IRS and, under
certain circumstances, provide for alternate examination
locations more favorable to the IRS if the IRS office closest to
the taxpayer’s home lacks the appropriate personnel to conduct
the investigation. We conclude that a similar framework also
applies in the context of an Appeals hearing under section
6320(b).11
From the record, it appears that the Appeals Office closest
to the residence of petitioner is the Appeals Office in Sunrise,
Florida. Petitioner has not alleged that there is an Appeals
Office in West Palm Beach or one closer to his residence.
Petitioner alleged in one of his letters to the Appeals officer
only that he could not “appear with [his] witnesses” when the
10 Sec. 301.7605-1(e)(2), Proced. & Admin. Regs., lists the
circumstances in which the Internal Revenue Service (IRS) will
normally permit transfers.
11 Sec. 6330(b) (which is almost identical to sec. 6320(b))
allows a taxpayer to have an Appeals hearing with regard to a
proposed levy. Because Appeals hearings pursuant to secs.
6320(b) and 6330(b) have the same function and scope, the
framework we apply to an Appeals hearing under sec. 6320(b) also
applies to an Appeals hearing under sec. 6330(b).
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