- 16 - 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).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: November 10, 2007