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P does not have a right to audio record the hearing
because it is not an “interview” within the meaning of
sec. 7521(a)(1), I.R.C.
Held, P is entitled, pursuant to sec. 7521(a)(1),
I.R.C., to make an audio recording of his sec. 6330
hearing with the Internal Revenue Service Appeals
Office.
Curtis B. Keene, pro se.
Rollin G. Thorley and Robin Ferguson, for respondent.
OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4), and Rules 180, 181, and 182.1 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion for Summary Judgment, filed pursuant to
Rule 121. The only issue raised by the parties is whether,
pursuant to the provisions of section 7521(a)(1), petitioner is
entitled to audio record his section 6330 hearing with the
Internal Revenue Service Appeals Office.
1 All Rule references are to the Tax Court Rules of
Practice and Procedure, and, unless otherwise indicated, all
section references are to the Internal Revenue Code, as amended.
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Last modified: May 25, 2011