Gary Wright - Page 11

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          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 section 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?                                        
                    A-D7.  The taxpayer must be offered an opportunity                
               for a hearing at the Appeals office closest to                         
               taxpayer’s residence or, in the case of a business                     
               taxpayer, the taxpayer’s principal place of business.                  
               If that is not satisfactory to the taxpayer, the                       
               taxpayer will be given an opportunity for a hearing by                 
               correspondence or by telephone.  If that is not                        
               satisfactory to the taxpayer, the Appeals officer or                   
               employee will review the taxpayer’s request for a CDP                  
               hearing, the case file, any other written                              
               communications from the taxpayer (including written                    
               communications, if any, submitted in connection with                   
               the CDP hearing), and any notes of any oral                            
               communications with the taxpayer or the taxpayer’s                     
               representative.  Under such circumstances, review of                   
               those documents will constitute the CDP hearing for the                






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