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provided petitioner with a hearing in response to his
disagreement with the collection action.
II. Whether Respondent Failed To Adopt or Employ Uniform
Rules or Procedures for the Hearing Pursuant to
Sections 6320 and/or 6330; Whether the Administrative
Procedures Act Applies to the Hearings; and Whether It
Is Respondent’s Obligation To Record the Hearing
Petitioner makes the vague argument that no uniform rules or
procedures existed for the conduct of the administrative hearing
and/or that he was not apprised of same. Respondent counters
that there were available to petitioner, in addition to the
above-referenced statutes, section 301.6320-1, et seq., Proced. &
Admin. Regs., and section 301.6330-1, et seq., Proced. & Admin.
Regs., which provide rules and procedures for the hearing and the
related process. We agree with respondent and find petitioner’s
contention to be without merit or substance.
Petitioner also contends that the provisions of the
Administrative Procedure Act, 5 U.S.C. sec. 551-557 (1994)
should apply to the sec. 6320/6330 hearing. Respondent has
stated in procedural regulations that a hearing under sections
6320 and 6330 is not under the formal hearing provisions of the
Administrative Procedure Act. See sec. 301.6320-1(d)(2), Q&A-D6,
Proced. & Admin. Regs.; sec. 301.6330-1(d)(2), Q&A-D6, Proced. &
Admin. Regs. Petitioner complained that the hearing was not
recorded by respondent, but petitioner did not seek, nor was he
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