Louis A. and Christine Cox - Page 19

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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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