- 13 - 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).Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011