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under sections 6502, 6531, or 6532 are suspended for the same
period. Sec. 6330(e)(1).
Whereas the above-stated rules for a Hearing are provided
explicitly in the statute, the rules for an equivalent hearing
have their genesis in the statute’s legislative history and the
regulations implementing Congressional intent as gleaned from
that history. See H. Conf. Rept. 105-599, at 266 (1998); 1998-3
C.B. 1020 (in the event that a taxpayer does not timely request a
Hearing, “The Secretary must provide a hearing equivalent to the
hearing if later requested by the taxpayer”); cf. Johnson v.
Commissioner, 86 AFTR 2d 2000-5225, 2000-2 USTC par. 50,591 (D.
Or. 2000) (“‘equivalent hearing’ is provided for only by
regulation and is not mandated by Section 6330 itself”). The
scheme of the regulations as they apply to equivalent hearings
generally follows the statutory scheme for Hearings.
Under the regulations, any taxpayer who fails to timely
request a Hearing may receive an equivalent hearing. Sec.
301.6330-1(i)(1), Proced. & Admin. Regs. The equivalent hearing
(like the Hearing) is held with Appeals, and the Appeals officer
considers the same issues which he or she would have considered
had the equivalent hearing been a Hearing. Id. The Appeals
officer also generally follows the same procedures at an
equivalent hearing which he or she would have followed had the
equivalent hearing been a Hearing. Id. Although the Appeals
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