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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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