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type of hearing with the Appeals officer or indicate any times
when petitioner would be available to speak to the Appeals
officer. On the record before us, we reject any contention of
petitioner that section 6330 entitled her to a face-to-face,
albeit informal, hearing, which the Appeals officer refused to
grant her.13
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining in the notice of determination to proceed with
collection with respect to each of petitioner’s taxable years
1992 and 1995.
We have considered all of petitioner’s contentions and
arguments that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing,
Decision will be entered
for respondent.
13Although not altogether clear, petitioner may also be
contending that sec. 6330 requires that a hearing between a
taxpayer and an Appeals officer take place in all events. We
reject any such contention. There is no requirement in sec. 6330
that an Appeals officer hold a hearing with a taxpayer who does
not want one. We have found in the instant case that the Appeals
officer provided petitioner with the opportunity to have a
telephonic conference with him, that she declined that opportu-
nity, and that she never requested a face-to-face, instead of a
telephonic, hearing.
Moreover, we are not persuaded that it would be necessary or
productive to remand this case to the IRS Appeals Office.
Lunsford v. Commissioner, 117 T.C. 183, 189 (2001).
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