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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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