- 10 -
Commissioner, supra at 121; Guthrie v. Sawyer, 970 F.2d 733, 737-
738 (10th Cir. 1992); Geiselman v. United States, 961 F.2d 1, 6
(1st Cir. 1992); Hughes v. United States, 953 F.2d 531, 535 (9th
Cir. 1992); United States v. Chila, 871 F.2d 1015, 1017-1018
(11th Cir. 1989). In Davis v. Commissioner, supra, the taxpayer
failed to demonstrate any irregularity in the assessment
procedure, and we granted respondent’s motion for a judgment on
the pleadings. We held further that Appeals hearings were
intended by Congress to be informal and do not require testimony
under oath or the compulsory attendance of witnesses or the
production of all requested documents. Id. at 41-42.
In this case, petitioners were provided with a Form 4340
which showed the assessment date of the taxes in question. The
Appeals officer relied on the Form 4340 to verify that section
6203 and the applicable regulations thereunder were satisfied.
Petitioners have not pointed to any alleged facts or evidence to
suggest that there were any irregularities in the assessment
process.
The only substantive issue that petitioners have raised in
this judicial proceeding is whether the Appeals officer properly
relied on a Form 4340 to verify under section 6330(c)(1) that the
taxes were properly assessed. We do not construe the instant
appeal as being predicated on allegations that respondent failed
to offer petitioners a hearing per se. Rather, the gist of
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