- 29 - section 6330 hearing before an impartial Appeals officer for purposes of section 6330(b)(3), and we conclude that petitioner’s aforementioned contentions are now moot. See Sapp v. Commissioner, T.C. Memo. 2006-104. B. Whether Petitioner’s Fifth Amendment Right to Due Process Was Violated. Petitioner also contends that his Fifth Amendment right to due process was violated by the absence of “recognizable” procedures to be followed in the section 6330 hearing. The Secretary, however, has promulgated regulations to govern section 6330 hearings, see sec. 301.6330-1, Proced. & Admin. Regs., and respondent’s Internal Revenue Manual sets forth related administrative procedures in detail, 4 Administration, Internal Revenue Manual (CCH), sec. 8.7.2.3. to 8.7.2.3.14. Petitioner fails to specify how such regulations and procedures are inadequate or even to acknowledge their existence. Under the circumstances of the instant case, we conclude that petitioner’s Fifth Amendment right to due process was not violated. See Rule 142(a). C. Whether Petitioner Submitted a Viable Offer-in-Compromise. We understand petitioner to contend further that he submitted a viable collection alternative for consideration and that Settlement Officer O’Shea and Appeals Officer Kaplan did not balance the need for the efficient collection of taxes withPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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