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regulation sections 301.6320-1(a)(2) Q&A-A10 and 301.6330-1(a)(3)
Q&A-A7. In that regard, petitioner was sent Publication 1660,
with the August 4, 2004, Letter 3172, Notice of Federal Tax Lien
Filing and Your Right To A Hearing Under IRC 6320. Publication
1660 describes the Appeals rights available to taxpayers, along
with mention of hearing issues provided for in sections 6320(c)
and 6330(c). In addition, the Appeals officer explained the
hearing process to petitioner and encouraged him to provide
additional information or issues. Accordingly, there is little
for petitioner to complain about in the setting of this case.
Further, it has been held that an Appeals officer’s failure to
provide a taxpayer with a written set of all rules, regulations,
and procedures applying to section 6320 and section 6330 hearings
was not an abuse of discretion. See Davis v. Commissioner, supra
at 41-42; Lindsay v. Commissioner, T.C. Memo. 2001-285; see also
Wylie v. Commissioner, T.C. Memo. 2001-65.
With respect to whether respondent can use information
obtained at a section 6320/6330 hearing to advance subsequent
collection, again petitioner did not provide any statute,
regulation, or precedent that would prevent respondent from doing
so. Respondent contends that he is not so limited, but that he
was not aware of any such use in this case. We agree with
respondent that no such limitation has been shown to exist.
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