Sue Taylor - Page 7

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          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.                                               












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