Richard H. Frank and Tammy J. Frank - Page 9




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               On the record before us, we shall grant respondent’s motion.           
               To reflect the foregoing,                                              
                                             An order granting respondent’s           
                                        motion and decision will be entered           
                                        for respondent.                               
























               7(...continued)                                                        
          lishes that petitioners never advised the Appeals officer that              
          they objected to the telephonic hearing scheduled for that date             
          and requested a face-to-face hearing.  In fact, neither Mr. Frank           
          nor Ms. Frank responded to the Appeals officer’s December 7, 2000           
          letters scheduling a telephonic hearing.  Although the record               
          does not disclose why Ms. Frank did not participate in the                  
          telephonic hearing scheduled by the Appeals officer, Mr. Frank              
          participated in that hearing.  On the record before us, we reject           
          any contention of petitioners that sec. 6330 entitled them to a             
          face-to-face hearing in the instant case.                                   





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