Curtis B. Keene - Page 1

                                   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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