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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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