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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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