Sam E. Scott - Page 16




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         denied the opportunity, to record the hearing.7  In Davis v.                 
         Commissioner, 115 T.C. 35, 41-42 (2000), we emphasized that the              
         hearing process is informal and does not require testimony under             
         oath or certain other formalities.  Petitioner does not raise any            
         other specific or particular aspect of the Administrative                    
         Procedure Act that should have been applied, and, in any event,              
         he did not say in what manner it would have made a difference in             
         this case if such procedures had been followed.  Accordingly, we             
         find no merit in these contentions.                                          
              III.  Whether Respondent Was Required To Provide Petitioner             
                    With Specific Information About the Rules,                        
                    Regulations, and or Procedures Governing Hearings; and            
                    Whether There Is Any Limitation on Respondent’s Use of            
                    Information Gained at the Hearing To Further                      
                    Subsequent Collection of the Tax                                  
              Although contending that respondent is required to provide              
         taxpayers with specific information about the rules, regulations,            
         and/or procedures governing hearings, petitioner has not cited               
         any statute, regulation, or case that mandates such a                        
         requirement.  Respondent contends that no such requirement                   
         exists.  Section 6331(d)(4) requires the Internal Revenue Service            
         to inform a taxpayer in nontechnical terms of the administrative             
         appeal rights available with respect to a levy.  Similar                     
         obligations, respecting liens, as well as levies, are imposed by             

               7 At the time of petitioner’s hearing, this Court had                  
          decided that taxpayers, in certain circumstances, have the right            
          to record a sec. 6320/6330 hearing.  Keene v. Commissioner, 121             
          T.C. 8 (2003).                                                              





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