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2. The Appeals Hearing
Even though petitioner’s hearing took place through
correspondence, as he requested, he asserts that he is entitled
to a face-to-face hearing he originally requested. A face-to-
face meeting is not invariably required. Hearings conducted
under section 6330 are informal proceedings, not formal
adjudications. Katz v. Commissioner, 115 T.C. 329, 337 (2000);
Davis v. Commissioner, 115 T.C. 35, 41 (2000). Hearings may be
held as face-to-face meetings, and they may also be conducted by
telephone 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, -D7, Proced. & Admin. Regs.
In light of petitioner’s specious arguments, a face-to-face
hearing in this case would not be productive. See Lunsford v.
Commissioner, supra at 189; Kemper v. Commissioner, supra. The
Appeals officer was willing to have a face-to-face hearing if
petitioner had raised any meaningful issue regarding his tax
liability or the proposed levy. Furthermore, petitioner was also
given the opportunity to discuss the collection of his 1998 tax
liability in two scheduled telephone hearings, and he simply
declined to do so. He again failed to raise any meaningful
issue, explain his position, or offer an alternative means of
collection when he was given the opportunity to do so by
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