121 T.C. No. 2
UNITED STATES TAX COURT
CURTIS B. KEENE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11604-02L. Filed July 8, 2003.
P filed a petition for levy action under sec.
6330(d), I.R.C., disputing R’s notice of determination
concerning collection action with respect to his 1991
tax liability on the ground that he was not permitted
by the IRS Appeals Office to make an audio recording of
his sec. 6330 hearing, in violation of sec. 7521(a)(1),
I.R.C. Subsequently, P filed an amended petition again
asserting his claimed right to audio record such
hearing. P had previously submitted documents to R in
his request for a collection due process hearing that
asserted several frivolous and groundless arguments. R
informed P by letter that he could make no audio
recording. P gave R the required advance request to
record. P appeared for the hearing but was told by R
that he could not record it. P decided that he did not
want to have a hearing if he could not record it, and
he left with his recording equipment. P contends that
sec. 7521(a)(1), I.R.C., provides him with the right to
audio record his sec. 6330 hearing because it
constitutes an “in-person interview”. R contends that
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