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their residence. Where the taxpayer declines to participate in a
proffered face-to-face hearing, hearings may also be conducted by
telephone or 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. Commissioner, T.C. Memo. 2004-25,
affd. 130 Fed. Appx. 934 (9th Cir. 2005); Leineweber v.
Commissioner, T.C. Memo. 2004-17; Armstrong v. Commissioner, T.C.
Memo. 2002-224; Gougler v. Commissioner, T.C. Memo. 2002-185;
Mann v. Commissioner, T.C. Memo. 2002-48. Thus, a face-to-face
meeting is not invariably required.
Regulations promulgated under sections 6320 and 6330
likewise incorporate many of the foregoing concepts, as follows:
Q-D6. How are CDP hearings conducted?
A-D6. * * * CDP hearings * * * are informal in
nature and do not require the Appeals officer or
employee and the taxpayer, or the taxpayer’s
representative, to hold a face-to-face meeting. A CDP
hearing may, but is not required to, consist of a face-
to-face meeting, one or more written or oral
communications between an Appeals officer or employee
and the taxpayer or the taxpayer’s representative, or
some combination thereof. * * *
Q-D7. If a taxpayer wants a face-to-face CDP
hearing, where will it be held?
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