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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 with
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