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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.
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