1. Is the collection of tax penalties an exception to the requirements of due process, or does a citizen have a right to a hearing before the IRS seizes thousands, or even millions, of dollars in tax penalties?

2. If the citizen has a right to a hearing, does a meeting with an IRS Appeals Officer satisfy the requirement of a "meaningful" pre-collection hearing?

3. Does the IRS's broad interpretation of "substantially similar" render the penalty statute so vague and unpredictable that no person of "common intelligence" could anticipate what types of plans would need to be reported?

Is the collection of tax penalties an exception to the requirements of due process, or does a citizen have a right to a hearing before the IRS seizes thousands, or even millions, of dollars in tax penalties?