Louis A. and Christine Cox - Page 27

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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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