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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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