Curtis B. Keene - Page 44

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          majority what Congress meant when it used the phrase “in-person             
          interview” in section 7521.                                                 
               Section 7521(b)(1) provides:                                           
               SEC. 7521.  PROCEDURES INVOLVING TAXPAYER INTERVIEWS.                  
               (b) Safeguards.--                                                      
                    (1) Explanations of processes.--An officer or                     
               employee of the Internal Revenue Service shall before                  
               or at an initial interview provide to the taxpayer--                   
                         (A) in the case of an in-person interview                    
                    with the taxpayer relating to the determination of                
                    any tax, an explanation of the audit process and                  
                    the taxpayer’s rights under such process, or                      
                         (B) in the case of an in-person interview                    
                    with the taxpayer relating to the collection of                   
                    any tax, an explanation of the collection process                 
                    and the taxpayer’s rights under such process.                     
          Section 7521(b)(1) thus clearly describes what Congress intended            
          when it used the phrase “in-person interview” in section 7521.              
               Not only section 7521 itself, but the legislative history of           
          that section also is instructive in determining what Congress had           
          in mind when it used the phrase “in-person interview” in section            
          7521(a)(1).  The conference report relating to section 7521, H.             
          Conf. Rept. 100-1104, at 212-214 (1988), 1988-3 C.B. 473, 702-704           
          (conference report), provides in pertinent part:                            
               Prior to initial in-person audit interviews, the IRS                   
               must explain to taxpayers the audit process and                        
               taxpayers’ rights under that process.  In addition,                    
               prior to initial in-person collection interviews, the                  
               IRS must explain the collection process and taxpayers’                 
               rights under that process.  For this purpose, routine                  
               telephone conversations initiated by either the                        
               taxpayer or the IRS are not considered initial                         





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