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to be that the absence of a more formal record of the hearing or
any significant administrative record, coupled with vague and
conclusory notices of determination, prevents meaningful review.
As this Court has noted on a number of occasions, hearings
conducted under sections 6320 and 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). There
inheres no right to subpoena witnesses or documents in connection
with these hearings. Roberts v. Commissioner, 118 T.C. 365, 372
(2002), affd. 329 F.3d 1224 (11th Cir. 2003); Nestor v.
Commissioner, 118 T.C. 162, 166-167 (2002); Davis v.
Commissioner, supra at 41-42. Taxpayers are entitled to be
offered a face-to-face hearing at the Appeals Office nearest
their residence. Where the taxpayer declines to participate in a
proffered face-to-face hearing, hearings may also be conducted by
telephone or 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 and D7, Proced. & Admin. Regs. Furthermore, once
a taxpayer has been given a reasonable opportunity for a hearing
but has failed to avail himself or herself of that opportunity,
we have approved the making of a determination to proceed with
collection based on the Appeals officer’s review of the case
file. See, e.g., Taylor v. Commissioner, T.C. Memo. 2004-25,
affd. 130 Fed. Appx. 934 (9th Cir. 2005); Leineweber v.
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