- 13 - that described his appeal rights and invited him to raise issues, including the issues referred to in the relevant statutes. The Appeals officer encouraged petitioner on multiple occasions to simply raise the issues he wanted to present, noting that the hearing was intended to be informal and no formal set of procedures governed the hearing. Petitioner was nonresponsive and renewed the same argument on numerous occasions throughout the hearing. In Davis v. Commissioner, supra at 41-42, we emphasized that the hearing process was informal, did not require testimony under oath, and did not require the compulsory attendance of witnesses or the production of documents. See also Wylie v. Commissioner, T.C. Memo. 2001-65. The Appeals officer did not abuse his discretion in not giving to petitioner a set of procedures governing the hearing. Finally, in his response to respondent’s motion for summary judgment, petitioner suggests that the notice of determination is invalid because the Appeals Office failed to make a proper and complete record of the hearing. However, attached to petitioner’s response to respondent’s motion is what petitioner purports to be a transcription from a cassette tape recording of the Appeals hearing. We have considered the contents of this document. On the basis of the record, we conclude that the hearing requirements were met and that our judicial reviewPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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