Curtis B. Keene - Page 26

                                       - 26 -                                         
               2.   Welcoming a Transcript                                            
               Having a transcript of the section 6330 hearing will allow             
          us to perform better the review provided to taxpayers by section            
               Until now, in order to determine what issues taxpayers                 
          raised at the section 6330 hearing, the Court was faced with “he            
          said-she said” situations--needless “credibility contests”                  
          between the taxpayer and the Appeals officer.  In many cases this           
          contest was not fully developed because the only evidence                   
          submitted to determine what issues were raised at the hearing was           
          the notice of determination.                                                
               I have tried a number of cases in which it was difficult to            
          determine what issues the taxpayer raised at the section 6330               
          hearing.  Sometimes it is obvious that the Appeals officer had              
          extreme difficulty understanding what issues the taxpayer raised            
          at the hearing.  In those cases, we were left merely with the               
          confusing testimony of the taxpayer and the Appeals officer’s               
          testimony regarding what issues he or she “believed” the taxpayer           
               Instead of merely having the notice of determination or the            

          taxpayer must sign a written waiver.”), and A-D7, Proced. &                 
          Admin. Regs. (“The taxpayer must be offered an opportunity for a            
          hearing at the Appeals office closest to [sic] taxpayer’s                   
          residence or, in the case of a business taxpayer, the taxpayer’s            
          principal place of business.”) (Emphasis added.)                            

Page:  Previous  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  Next

Last modified: May 25, 2011