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petitioner that section 6330 does not afford him an unlimited
right to present information in person and at a time or place of
his choosing. If petitioner cannot promptly meet with an Appeals
officer to submit documentation and other pertinent data, we
would expect him to do so through a representative or by written
or telephonic communication. Otherwise, respondent will be in a
position to close petitioner’s 1999 case on the existing record.
In conclusion, with respect to 1985, the Court will sustain
respondent’s determination to proceed with collection action.
With respect to 1999, the Court will remand the case for further
proceedings, in the form of a section 6330 hearing, before
Appeals.
To reflect the foregoing,
An appropriate order will
be issued.
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