- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011