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 thatPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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