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score is necessary for us to review the determination. See Fed.
R. Evid. 403 (waste of time or needless presentation of
cumulative evidence grounds for excluding relevant evidence).
Ms. Boudreau’s case activity report does contain unexplained
notations and abbreviations, and her testimony is necessary to
explain those notations and abbreviations. Therefore, that
testimony is admissible.
It is also true, as petitioner claims, that there is no
transcript or recording of the hearing. No provision of section
6330 requires the recording of a section 6330 hearing, and, in
fact, section 301.6330-1(d)(2), A-D6, Proced. & Admin. Regs.,
states: “A transcript or recording of any face-to-face meeting
or conversation between an Appeals officer or employee and the
taxpayer or the taxpayer's representative is not required.”
Moreover, petitioner never asked to record Mr. Burke’s meeting
with Ms. Boudreau. Cf. Keene v. Commissioner, 121 T.C. 8, 19
(2003). Here, we need ascertain only whether Ms. Boudreau abused
her discretion when she did not accept a compromise based on
petitioner’s insistence that he could pay no more than
approximately 4 percent of his uncontested tax liability and
concluded that, under the circumstances, the use of the levy
process was “no more intrusive than necessary.” Sec. 6330(c).
Petitioner’s offer, his responses and lack thereof to Ms.
Boudreau’s requests, and her conclusions, are adequate for such
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