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the infirmities that petitioner claims justify the admission of
Ms. Boudreau’s testimony.
First, petitioner claims that the notice of determination
fails to state the current policies and procedures relied on by
Ms. Boudreau. We have summarized the contents of the notice of
determination (and attachment) in our findings of fact, and there
is no question but that it addresses all of the issues required
by law. See sec. 6330(c); sec. 301.6330-1(e)(3), A-E10 & A-E1,
Proced. & Admin. Regs. Moreover, as respondent points out on
brief, the policies and procedures of the IRS, as set forth in
the law, accompanying regulations, and Internal Revenue Manual,
are all available to the general public.8 Respondent concedes
that petitioner could have questioned Ms. Boudreau about any
policy or procedure that he believed she did not follow.
Instead, petitioner questioned her about her use of national
standards for determining necessary living expenses in evaluating
offers in compromise. Such a discussion is not relevant in this
particular case, argues respondent, because, with one exception,
Ms. Boudreau accepted the living expenses claimed by petitioner
in the collection information statements he submitted to her when
7(...continued)
2005); Orion Intl. Techs. v. United States, 60 Fed. Cl. 338, 343-
344 (2004).
8 See supra note 2 for direction to the Internal Revenue
Manual.
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