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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 would
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