Kenneth A. Schrems - Page 5




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          6330(c)(1).  Respondent verified the assessments with literal               
          transcripts, which were sent to petitioner’s attorney on June 28,           
          2001.  Kuglin v. Commissioner, T.C. Memo. 2002-51 (holding that             
          absent a showing of irregularity, transcripts that identify the             
          taxpayer, the character of the liability assessed, the taxable              
          period, and the amount of the assessment are sufficient to                  
          establish that a valid assessment was made).  Petitioner did not            
          provide any evidence of an irregularity in the assessment                   
          procedure that would raise a question about the validity of the             
          assessment.  Nestor v. Commissioner, 118 T.C. 162, 167 (2002).              

               Petitioner also contends that a section 6330 hearing before            
          an Appeals officer was not properly held.  Respondent offered               
          petitioner the opportunity to meet either in person or by                   
          telephone.  Petitioner declined because he was not allowed to               
          conduct discovery or to compel the appearance of witnesses.                 
          Respondent, however, had no obligation to provide the documents             
          requested by petitioner.  See Kuglin v. Commissioner, supra.                
          Moreover, petitioner does not have the right, in a section 6330             
          Appeals hearing, to subpoena witnesses.  Davis v. Commissioner,             
          supra.  Respondent did not abuse his discretion by issuing his              
          determination after petitioner refused to participate in the                
          Appeals hearing.  Accordingly, we sustain respondent’s                      
          determination.                                                              

               Contentions we have not addressed are irrelevant, moot, or             






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