- 10 - Petitioner argues that respondent failed to comply with the notice requirements of sections 6303, 6330, and 6331. Mr. Climan, however, verified that the proper assessments were made and the requisite notices had been sent to petitioner in accordance with section 6303.6 Moreover, the record clearly establishes that respondent provided petitioner with notice of his intent to levy and of petitioner’s right to a hearing as required by sections 6331 and 6330, respectively. Petitioner also asserts that respondent erred by changing settlement officers. We find this argument completely without merit, as the reassignment of petitioner’s case to Mr. Sample was done to accommodate petitioner’s own request to conduct the hearing at the Appeals Office located in Thousand Oaks. Petitioner failed to allege facts or demonstrate a connection as to how this reassignment impacts the validity of his section 6330 proceeding. Finally, petitioner claims that respondent violated petitioner’s right to procedural due process by refusing to allow him to make an administrative record of all of his issues. Petitioner argues that Mr. Sample’s decision to adjourn the Appeals hearing deprived him of a full and complete hearing. A 6 Mr. Climan confirmed that the Internal Revenue Service (IRS) issued notice and demand to petitioner for the years at issue by examining transcripts of account using the IRS’s integrated data retrieval system.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011