Travis D. Hiland - Page 11

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          that he was denied the collection hearing to which he was                   
          entitled and apparently seeks a remand to Appeals in order to               
          allow a conference to be held.  Relevant caselaw precedent and              
          regulatory authority, however, indicate that the circumstances              
          here are not such as to render remand appropriate.                          
               Hearings conducted under section 6330 are informal                     
          proceedings, not formal adjudications.  Katz v. Commmissioner,              
          115 T.C. 329, 337 (2000); Davis v. Commissioner, 115 T.C. 35, 41            
          (2000).  There exists no right to subpoena witnesses or documents           
          in connection with section 6330 hearings.  Roberts v.                       
          Commissioner, 118 T.C. 365, 372 (2002), affd. 329 F.3d 1224 (11th           
          Cir. 2003); Nestor v. Commissioner, 118 T.C. 162, 166-167 (2002);           
          Davis v. Commissioner, supra at 41-42.  Taxpayers are entitled to           
          be offered a face-to-face hearing at the Appeals Office nearest             
          their residence.  Where the taxpayer declines to participate in a           
          proffered face-to-face hearing, hearings may also be conducted              
          telephonically or by correspondence.  Katz v. Commissioner, supra           
          at 337-338; Dorra v. Commissioner, T.C. Memo. 2004-16; sec.                 
          301.6330-1(d)(2), Q&A-D6 and D7, Proced. & Admin. Regs.                     
          Furthermore, once a taxpayer has been given a reasonable                    
          opportunity for a hearing but has failed to avail himself or                
          herself of that opportunity, we have approved the making of a               
          determination to proceed with collection based on the Appeals               
          officer’s review of the case file.  See, e.g., Taylor v.                    






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