- 7 - with an in-person interview and upon advance request, will be allowed to make an audio recording of the interview. In this case, however, petitioner did not make a request to record, and as required in section 7521(a)(1), such requests must be made in advance. In her response to respondent’s motion for summary judgment, petitioner tacitly admits that she did not make a request to record the Appeals conference. Significantly, neither petitioner nor her representative attended the meeting with the Appeals officer, and neither of them requested or was refused the opportunity to record. Therefore, petitioner’s argument fails. Accordingly, we hold that there is no genuine issue as to any material fact supporting petitioner’s claim that there was an abuse of discretion in respondent’s determination concerning the collection action(s) under section 6320 and/or 6330. As such, we further hold that respondent is entitled to proceed with collection of petitioner’s 1997 tax liability. We have considered all of petitioner’s arguments, and, to the extent that they are not mentioned herein, we find them to be moot, irrelevant, or without merit.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011