[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.7458-1]

[Page 541]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                          Judicial Proceedings
 
Sec. 301.7458-1  Hearings.

    Notice and opportunity to be heard upon any proceeding instituted 
before the Tax Court shall be given to the taxpayer and the 
Commissioner. If an opportunity to be heard upon the proceeding is given 
before a division of the Tax Court, neither the taxpayer nor the 
Commissioner shall be entitled to notice and opportunity to be heard 
before the Tax Court upon review, except upon a specific order of the 
chief judge.