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Tax Lawyer, Vol. 61, No. 1 NOTES 303NOTETurn Off the Tape Recorder at Telephonic Collection Due Process Hearings: Why the District Court Was Wrong in Simien v. Internal Revenue ServiceI. Introduction Before the Service may levy the property of a taxpayer, the taxpayer has a due process right to a fair hearing (a collections due process or CDP hearinng with the Office of Appeals of the Service pursuant to section 6330.1 In Simien v. Internal Revenue Service,2 the District Court for the Western...