- 44 - 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 initialPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
Last modified: May 25, 2011