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Petitioner received statutory notices of deficiency for the
years in issue, and thus his underlying tax liability is not
properly at issue. Accordingly, we review respondent’s
determination for an abuse of discretion. See Sego v.
Commissioner, supra at 610; Goza v. Commissioner, supra at 181.
Petitioner argues that respondent abused his discretion by
not allowing petitioner a face-to-face hearing.
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); Ho v. Commissioner, T.C. Memo. 2006-41. Taxpayers are
generally entitled to a face-to-face hearing at the Appeals
Office nearest their residence. Sec. 301.6330-1(d)(2), Q&A D6
and D7, Proced. & Admin. Regs. Where the taxpayer declines to
participate in a proffered face-to-face hearing, hearings may be
conducted by telephone or correspondence. Katz v. Commissioner,
supra at 337-338; Ho v. Commissioner, supra; sec. 301.6330-
1(d)(2), Q&A-D6 and D7, Proced. & Admin. Regs. Furthermore, once
the taxpayer has been given reasonable opportunity for a hearing
but has failed to avail himself of that opportunity, we have
approved the making of a determination to proceed with collection
based on the Commissioner’s review of the case file. See, e.g.,
Ho v. Commissioner, supra; Taylor v. Commissioner, T.C. Memo.
2004-25, affd. 130 Fed. Appx. 934 (9th Cir. 2005); Leineweber v.
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