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          of the hearing should hinge on the amount of time necessary to              
          discuss “relevant” issues.  The advisory declares unequivocally             
          that:  “A taxpayer is entitled to a CDP hearing even if he [or              
          she] will raise only frivolous or constitutional arguments                  
          because the appeals officer must cover the statutory requirements           
          of sections [sic] 6330(c)(1) and (3)(C) of verification and                 
          balancing.”  (Emphasis added.)  Pursuant to the legislative                 
          mandate in section 6330(c)(1), “The appeals officer shall at the            
          hearing obtain verification from the Secretary that the                     
          requirements of any applicable law or administrative procedure              
          have been met.”  (Emphasis added.)  Pursuant to the legislative             
          mandate of section 6330(c)(3)(C), the Appeals officer must                  
          consider “whether any proposed collection action balances the               
          need for the efficient collection of taxes with the legitimate              
          concern of the person that any collection action be no more                 
          intrusive than necessary.”                                                  
               The fact that the majority does not give proper regard to              
          the Commissioner’s administrative practice is, to my mind, a                
          mistake.  Section 6330 is a relatively new provision, and the               
          Commissioner is obviously looking to the Courts for guidance as             
          to the proper rules which he must apply to implement that                   
          provision properly.  Given the fact that he has announced that he           
          is now providing a CDP hearing to all taxpayers who request one,            
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