- 22 -
Rule 121(a) and (b); Sundstrand Corp. v. Commissioner, 98 T.C.
518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). The moving
party bears the burden of proving that there is no genuine issue
of material fact, and factual inferences will be read in a manner
most favorable to the party opposing summary judgment. See
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner, 79 T.C. 340, 344 (1982).
In the amended petition filed March 18, 2005, petitioner
contends that he was denied a proper hearing under section 6330.
However, hearings conducted under section 6330 are informal
proceedings, not formal adjudications. Katz v. Commissioner, 115
T.C. 329, 337 (2000); Davis v. Commissioner, 115 T.C. 35, 41
(2000). Taxpayers are generally entitled to be offered a face-
to-face hearing at the Appeals Office nearest their residence.
Where the taxpayer declines to participate in a proffered face-
to-face hearing, hearings may be conducted telephonically or by
correspondence. Katz v. Commissioner, supra at 337-338; Dorra v.
Commissioner, T.C. Memo. 2004-16; sec. 301.6330-1(d)(2), Q&A-D6
and D7, Proced. & Admin. Regs. Furthermore, once a taxpayer has
been given a reasonable opportunity for a hearing but has failed
to avail himself of that opportunity, we have approved the making
of a determination to proceed with collection based on the
Appeals officer’s review of the case file. See, e.g., Taylor v.
Commissioner, T.C. Memo. 2004-25, affd. 130 Fed. Appx. 934 (9th
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