- 27 - situation where the specific year or years were the explicit target of an administrative proceeding. See sec. 301.6330- 1(d)(2), A-D4, Proced. & Admin. Regs. Stated otherwise, the regulations indicate that prior involvement as used in the section 6330 context does not arise where consideration of later years was peripheral to a proceeding the subject of which was an earlier year or years. Second, from a practical standpoint, the law clearly permits multiple collection hearings with respect to a given period to be conducted by the same Appeals officer when that period is, for example, the subject of multiple notices under section 6320 and/or 6330. Logically, then, it is difficult to argue that an appreciably greater or different harm could ensue where a period is first considered informally in the course of one collection proceeding initiated regarding another period and then becomes the direct subject of a subsequent proceeding. It would make little substantive sense to have operation of the exception turn on mere coincidences of timing in the issuance of the various actionable notices. In addition, given the practical realities that collection problems often develop or continue serially over a number of years and that many Appeals Offices are small with limited staff, a construction that could progressively disqualify an entire office vis-a-vis a taxpayer with multiple years in arrears wouldPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011