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the section 6330 hearing was a face-to-face meeting between the
taxpayer and the Appeals officer. In this case, the section 6330
hearing was telephonic and did not involve any face-to-face
meeting between petitioner and the Appeals officer. Respondent
argues that the term “in-person interview” in section 7521(a)(1)
requires a face-to-face meeting between the taxpayer and the
presiding Appeals officer. Petitioner contends, however, that
Keene confirms he is entitled to make an audio recording of his
section 6330 telephone hearing because the hearing relates to the
collection of tax and involves an exchange of information that
qualifies as an “in-person interview” as that term is used in
section 7521(a)(1) and that “it’s not an issue of whether it’s by
telephone or not”. We disagree with petitioner for the following
reasons.
First, petitioner’s position that Keene confirms he has a
right to audio record his section 6330 hearing pursuant to
section 7521(a)(1), regardless of whether it takes place face-to-
face, by telephone, or otherwise, is not persuasive. In Keene,
we held that section 7521(a)(1) entitled the taxpayer to audio
record his section 6330 hearing because the hearing was an “in-
person interview” with respect to the collection of tax. We
concluded that the hearing had the characteristics of a section
7521(a)(1) “in-person interview”, in part, specifically because
the hearing “between the taxpayer and the Appeals officer is
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