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law sustaining the notice of determination dated June 11, 2002.
Respondent’s position is that section 7521(a)(1),3 which
authorizes taxpayers to record “in-person interviews”, is not
applicable to hearings pertaining to collection actions under
section 6320 or 6330. Petitioner filed an objection to
respondent’s motion.
This matter was called for hearing at the Court’s motions
session held in Washington, D.C. Counsel for respondent appeared
at the hearing and was heard. Although there was no appearance
by or on behalf of petitioner at the hearing, he filed with the
3 Sec. 7521, which is entitled “Procedures Involving
Taxpayer Interviews”, provides in part:
SEC. 7521(a) Recording of Interviews.--
(1) Recording by Taxpayer.–-Any officer or
employee of the Internal Revenue Service in connection
with any in-person interview with any taxpayer relating
to the determination or collection of any tax shall,
upon advance request of such taxpayer, allow the
taxpayer to make an audio recording of such interview
at the taxpayer’s own expense and with the taxpayer’s
own equipment.
(2) Recording by IRS Officer or Employee.–-An
officer or employee of the Internal Revenue Service may
record any interview described in paragraph (1) if such
officer or employee--
(A) informs the taxpayer of such recording
prior to the interview, and
(B) upon request of the taxpayer, provides the
taxpayer with a transcript or copy of such recording
but only if the taxpayer provides reimbursement for the
cost of the transcription and reproduction of such
transcript or copy.
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