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sec. 6320(b) (relating to liens), and the right to Court review
of a determination made by that office under section 6330(c),
sec. 6330(d)(1). Consequently, in order to analyze properly the
meaning of the phrase “in-person interview” in section
7521(a)(1), it is necessary to undertake such an analysis in the
context of hearings or conferences historically conducted before
Appeals, which were extant in 1988 when Congress enacted section
7521 as part of TAMRA and which we held in Davis v. Commissioner,
supra, were the types of informal administrative Appeals hearings
that Congress contemplated when it enacted section 6330(b). It
is inappropriate to analyze, as the majority does, the meaning of
the phrase “in-person interview” in the context of reasons
grounded in the operation and purpose of section 6330 (and
section 6320), which Congress did not make part of the Code until
10 years after it enacted section 7521.
The majority begins its analysis of the meaning of the
phrase “in-person interview” in section 7521(a)(1) by stating:
Neither section 7521(a)(1) nor the legislative history
directly and clearly defines or otherwise describes the
term “in-person interview”. Where a term is not
defined in the statute, it is appropriate to accord the
term its “ordinary meaning”. Northwest Forest Resource
Council v. Glickman, 82 F.3d 825, 833 (9th Cir. 1996).
And when there is no indication that Congress intended
a specific legal meaning for the term, courts may look
to sources such as dictionaries for a definition.
Muscarello v. United States, 524 U.S. 125, 127-132
(1998); see also Huntsberry v. Commissioner, 83 T.C.
742, 747-748 (1984), in which the Court stated that
“where a statute is clear on its face, * * * we would
require unequivocal evidence of legislative purpose
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