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(1st Cir. 2005). Petitioners look to Mesa Oil, Inc. v. United
States, 86 AFTR 2d 2000-7312, at 2000-7317, 2001-1 USTC par.
50,130, at 87,101 (D. Colo. 2000), for support, but even the
District Court in that case stated:
The government is correct that these rulings and
provisions support the informal nature of the hearing.
Yet informality does not completely obviate the need
for a record of some sort. While a full stenographic
record is not required, there must be enough
information contained in the documentation created by
the IRS for a court to draw conclusions about statutory
compliance and whether the AO abused his or her
discretion. * * *
Here, the parties have stipulated and included in the record
the full Appeals Office administrative file, including the
collection function investigative file incorporated therein, for
each of the years in issue. These materials contain extensive
contemporaneous notes by IRS personnel as well as the
correspondence between the parties. Mr. Skidmore’s notes of what
transpired at the section 6330 hearings are a notable feature of
this compendium. Taken together, the assemblage provides a
singularly clear portrayal of administrative developments as they
occurred. In addition, petitioners do not contend ever to have
made a request under section 7521 to record the hearing. On the
facts of these cases, the Court is satisfied that the
administrative record is adequate for proper judicial review.
See Living Care Alternatives of Utica, Inc. v. United States,
supra at 629-630 (distinguishing Mesa Oil, Inc. v. United States,
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