Edward W. Clough - Page 11

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         present any credible evidence that notice and demand was not                 
         issued as indicated on the Forms 4340.  Consequently, we conclude            
         that notices and demands were properly issued to petitioner with             
         respect to the 1996-98 liabilities.                                          
                   3.  Section 6330 Hearing                                           
              Lastly, petitioner argues that he was denied a proper                   
         section 6330 hearing.  Petitioner’s principal argument is that               
         respondent improperly denied him a face-to-face section 6330                 
         hearing.  We have held repeatedly that because a hearing                     
         conducted under section 6330 is an informal proceeding instead of            
         a formal adjudication, a face-to-face hearing is not mandatory.              
         See Katz v. Commissioner, 115 T.C. 329, 337 (2000); Davis v.                 
         Commissioner, supra at 41.  Accordingly, while a hearing may take            
         the form of a face-to-face meeting, a proper section 6330 hearing            
         may also be conducted by telephone or written correspondence.                
         Katz v. Commissioner, supra at 337-338; sec. 301.6330-1(d)(2),               
         Q&A-D6, Proced. & Admin. Regs.  Once a taxpayer is given a                   
         reasonable opportunity for a hearing and fails to avail himself              
         of that opportunity, this Court has sustained respondent’s                   
         determination to proceed with collection based upon an Appeals               
         officer’s review of the case file.  See, e.g., Bean v.                       

          245, affd. 72 Fed. Appx. 729 (9th Cir. 2003).                               

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