- 6 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 Next
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