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an accurate record of the hearing to be made by me. I
received a copy of IRS Publication 1 (Your Rights as a
taxpayer), which clearly states that I have a right to
record such proceedings.
On October 3, 2002, the Appeals officer held an Appeals
Office hearing with petitioner with respect to the notice of
intent to levy. Cheryl Flathers (Ms. Flathers) accompanied
petitioner to that hearing. Although petitioner and Ms. Flathers
both knew that the Appeals Office no longer allowed audio record-
ings of Appeals Office hearings, petitioner and/or Ms. Flathers
secretly made an audio recording of petitioner’s Appeals Office
hearing.4 At the Appeals Office hearing, the Appeals officer
gave petitioner Form 4340, Certificate of Assessments, Payments,
and Other Specified Matters (Form 4340), with respect to peti-
tioner’s taxable year 1998.
On October 29, 2002, the Appeals Office issued to petitioner
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to that notice stated in pertinent part:
Verification of Legal and Procedural Requirements
The requirements of all applicable laws and administra-
tive procedures have been met:
The liabilities were assessed and notice and
4Ms. Flathers, who is no stranger to respondent’s Appeals
Office or the Court, made a secret recording of her own hearing
that respondent’s Appeals Office held with her pursuant to secs.
6320(b) and 6330(b) on May 16, 2002. Flathers v. Commissioner,
supra.
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