- 21 - revd. 439 F.3d 455 (8th Cir. 2006). Congress enacted section 6330 as a part of remedial legislation, the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, 112 Stat. 685, to ensure taxpayer rights against alleged Internal Revenue Service mistreatment by affording taxpayers “formal procedures designed to ensure due process where the IRS seeks to collect taxes by levy (including by seizure).” S. Rept. 105-174, at 67 (1998), 1998-3 C.B. 537, 603. Because I believe that due process in formal judicial actions may need to include the right to call witnesses where that right was not previously afforded and facts are in dispute, I continue to believe that Robinette was correctly decided. HAINES, J., agrees with this concurring opinion.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: November 10, 2007