- 6 - Petitioner also contends that he was not given a hearing as required by section 6330. Respondent contends that the Appeals officer scheduled a hearing and provided petitioner with written notice of the hearing. Petitioner has not contended that he did not receive notice of the scheduled hearing. Petitioner did not attend the scheduled hearing and did not attempt to reschedule the hearing. The Court agrees with respondent that petitioner was granted an opportunity for a hearing. Accordingly, we hold that respondent’s determination to proceed with the levy is not an abuse of discretion. Issue 2. Section 6673(a)(1) Penalty We decline to impose a penalty under section 6673(a)(1). Contentions we have not addressed are irrelevant, moot, or meritless. To reflect the foregoing, An appropriate order will be issued, and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011