Louis A. and Christine Cox - Page 17

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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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