- 12 - As we noted in Davis v. Commissioner, 115 T.C. 35, 41 (2000), procedures in collection hearings under section 6330 were intended by Congress to be handled in a manner similar to procedures used in traditional Appeals hearings. For years, as far as I know without exception and long before enactment of sections 6320 and 6330, respondent’s audit and Appeals representatives, in all collection contexts, have provided to taxpayers copies of transcripts of account and of Forms 4340 relating to the taxpayers. I hope that this opinion will not be read to suggest that such documents, easily and routinely obtained by respondent’s collection personnel and by respondent’s Appeals officers, need no longer be made available to taxpayers and to their representatives, particularly in collection contexts. The new collection procedures under sections 6320 and 6330 should not be interpreted to change the routine availability to taxpayers from respondent's representatives of transcripts of account and of Forms 4340. In light of comments made in Judge Foley’s dissenting opinion regarding the relationship of the verification requirements of section 6330(c)(1) with taxpayers’ rights under section 6203 (and the related regulations) to obtain from respondent a copy of the “record of the assessment”, some further comments are appropriate regarding those two quite differentPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011