Alan R. Wylie - Page 6

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          for the purpose of complying with section 6330(c)(1) and section            
          301.6330-1T(e)(1), Temporary Proced. & Admin. Regs., supra.  See            
          Davis v. Commissioner, supra.                                               
               We find petitioner’s allegations contained in paragraph (b),           
          set out above, to be unsupported by the record.  On March 30,               
          2000, petitioner’s representative was notified that a collection            
          due process hearing would be held on April 26, 2000.  At                    
          petitioner’s request, the hearing was rescheduled on April 18,              
          2000, and held on May 12, 2000.  Petitioner was represented at              
          the hearing by Thomas Roberts, C.P.A., and Richard Miller, C.P.A.           
          We find as a fact that the Appeals officer furnished a Form 4340            
          at the hearing and notified petitioner of the time and date of              
          the hearing.  We hold that respondent provided petitioner with              
          all required documents and provided adequate notice of the                  
          hearing to petitioner.                                                      
               Petitioner’s final allegation of error is that he was                  
          precluded from gaining access to documents and not allowed to               
          cross-examine witnesses.  We rejected these same arguments in               
          Davis v. Commissioner, supra, and the reasoning stated therein is           
          equally applicable here.                                                    

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