§557

James M. Robinette, Petitioner 123 T.C. No. 5 · 2004

329, 337 (2000), we held that the Appeals officer may conduct the hearing by telephone. In Nestor v. Commissioner, 118 T.C. 162, 166-167 (2002), we held that the IRS was not required to provide assessment records to the taxpayer at the hearing. In some instances, we have affirmed the Appeals officer's determination when no hearing was conducted. See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001). In Keene v. Commissioner, 121 T.C. 8 (2003), we held that while the IRS is not required to recor

Suzanne L. Porter a.k.a. Suzanne L. Holman, Petitioners 130 T.C. No. 10 · 2008

556, which provides the rules for hearings conducted under APA sections 553 and 554, explains the contents of the record as follows : (e) The transcript of testimony and exhibits, together with all papers and requests filed in the proceeding, constitutes the exclusive record for decision in accordance with section 557 of this title and, on payment of lawfully prescribed costs, shall be made available to the parties .

Porter v. Commissioner 130 T.C. 115 · 2008

556, which provides the rules for hearings conducted under APA sections 553 and 554, explains the contents of the record as follows: (e) The transcript of testimony and exhibits, together with all papers and requests filed in the proceeding, constitutes the exclusive record for decision in accordance with section 557 of this title and, on payment of lawfully prescribed costs, shall be made available to the parties.

James J. Flanagan Stevedores, Inc. v. Gallagher 219 F.3d 426 · Cir.

Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, and Naomi Kanter v. Commissioner of Internal Revenue 337 F.3d 833 · Cir.

Robinette v. Commissioner 123 T.C. 85 · 2004

Hillsboro National Bank v. Commissioner 73 T.C. 61 · 1979

Farnsworth v. Commissioner 29 T.C. 1131 · 1958

Estate Burton Kanter v. CIR · Cir.

Lin v. Lynch · Cir.

United States v. Diane Davis 815 F.3d 253 · Cir.

Craft v. United States 233 F.3d 358 · Cir.

Jobst W.F. Blachy v. Robert E. Butcher and Rosemary Butcher, Co-Personal Representatives of the Estate of Alexander Michael Butcher, Deceased Rosemary Butcher, Individually Little Traverse Development Company, a Michigan Corporation H.C. Development Company, a Michigan Corporation, (99-1185/1492) 221 F.3d 896 · Cir.

Sandra L. Craft, Plaintiff-Appellee/cross-Appellant v. United States of America, Acting Through the Commissioner of Internal Revenue, Defendant-Appellant/cross-Appellee 233 F.3d 358 · Cir.

14 Citing Cases

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