at 6 (citing Davis v. Comm’r, 115 T.C. 35, 2000 WL 1048515 (2000); Katz v. Comm’r, 115 T.C. 329, 2000 WL 1520318 (2000) (Katz); Konkel v. Comm’r, 2000 WL 1819417 (M.D.Fla.2000) (Konk-el)). In Katz, 115 T.C. at 335, the tax court held that a meaningful hearing, pursuant to § 6330, does not include the right to “subpoena witnesses and documents.” The tax court further stated that the “nature of the [a]ppeals process does not include the taking of testimony under oath or the compulsory attendance of witnesses.” Id. (citation omitted). The tax court noted that appeals hearings historically have been conducted in an informal manner, and that “nothing in section 6330 or the legislative history indicated Congress intended to alter this format.” Id.; see also Konkel, 2000 WL 1819417, at *4 (<HOLDING>). The court notes that § 6320 and § 6330
holding that the legislative history under the act indicates that liquidated damages are intended to be punitive in nature holding that if federal income tax statutes are intended to benefit anyone it is the federal government to whom the withheld tax is to be remitted there is no indication anywhere in the language of the statutes that congress intended to confer rights on employees with respect to the withholding of tax holding that where there is no suggestion in the text legislative history or purpose of the flsa that congress intended to confer a nonwaivable right to a class action a plaintiffs inability to bring a class action cannot by itself suffice to defeat the strong congressional preference for an arbitral forum holding that there is no due process right to appellate review holding that there is no indication in the legislative history or the language of  6330 that congress intended for taxpayers to have the right to subpoena witnesses or documents at a collection due process hearing