- 5 - 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, orPage: Previous 1 2 3 4 5 6 Next
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