- 45 - interviews. A written statement handed to the taxpayer at an audit or collection interview or within a short time before the interview is sufficient. * * * H. Conf. Rept. 100-1104, at 213 (1988), 1988-3 C.B. 473, 703. Section 7521(b)(1) and the conference report make clear that, when Congress used the phrase “in-person interview” in section 7521, it did not have in mind either the dictionary definition of the term “interview” on which the majority improperly relies or the historically voluntary and informal hearings or conferences before Appeals. The descriptions by Congress in section 7521 itself and its legislative history leave no doubt that what Congress meant when it used the phrase “in- person interview” in section 7521, including section 7521(a)(1), is an in-person audit interview and an in-person collection interview, which take place during the audit process and the collection process, respectively, and the function of which is to investigate and determine facts relating to the determination and the collection of any tax. Thus, it makes perfect sense that Congress decided in section 7521 to allow taxpayers, sec. 7521(a)(1), as well as the IRS, sec. 7521(a)(2), to record such types of interviews. That is because in-person audit interviews and in-person collection interviews are interviews initiated by the IRS that taxpayers are under some compulsion to attend and that the IRS conducts for the purpose of gathering information to use in the determination of and the collection of tax,Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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