Roy Watson - Page 7




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          III.  Petitioner’s Claims                                                   
               A.  Meaningful Hearing                                                 
               In the petition, petitioner claims that he was not afforded            
          a meaningful hearing on all of the facts of the case, apparently            
          because respondent erred in failing to allow petitioner the right           
          to examine documents, present his case as he saw fit, and cross-            
          examine witnesses.  In Davis v. Commissioner, 115 T.C. 35, 41-42            
          (2000), we rejected similar claims, finding that, in providing to           
          a person the right to request a section 6330(b) hearing, Congress           
          intended an informal administrative hearing, of the type that,              
          traditionally, had been conducted by appeals and was prescribed             
          by section 601.106(c), Statement of Procedural Rules.  We held              
          that the right to a section 6330(b) hearing does not include the            
          right to subpoena witnesses.  Id. at 42.  We stated:  “The nature           
          of the administrative Appeals process does not include the taking           
          of testimony under oath or the compulsory attendance of                     
          witnesses.”  Id.  at 41-42.  We concluded that the taxpayer could           
          have a meaningful hearing without being accorded rights to                  
          subpoena witnesses and documents.  Id.  Petitioner has failed to            
          demonstrate that he is entitled to any relief on account of his             
          claim that respondent erred in failing to allow him the right to            
          examine documents, present his case as he saw fit, and cross-               
          examine witnesses.                                                          








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