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Sego v. Commissioner, supra at 610. The Court reviews other
administrative determinations regarding the proposed levy action
for abuse of discretion. Id.
In the present case, the only issue that petitioner raises
is that respondent failed to provide a section 6330 hearing to
petitioner. Petitioner does not challenge the existence of the
underlying tax liability. Accordingly, we review respondent’s
determination to proceed with the levy action for abuse of
discretion.
Petitioner contends that it was an abuse of discretion for
respondent to treat the two telephone conversations between Mr.
Taggart and Appeals Officer Melick as a section 6330 hearing. By
failing to provide a section 6330 hearing, petitioner argues,
respondent prevented petitioner from presenting the factual
information and documentation that she had proposed to submit in
support of her offer in compromise. Petitioner further asserts
that, because respondent did not consider petitioner’s factual
information and documentation, respondent lacked a sufficient
basis for determining that the levy action could proceed.
In response, respondent contends that telephone conferences
are an acceptable format for section 6330 hearings and that the
two telephone conversations between Mr. Taggart and Appeals
Officer Melick qualified as a section 6330 hearing. According to
respondent, during the telephone conversations, Mr. Taggart and
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