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schedule his hearing. In a letter dated August 4, 2002,
petitioner informed the Appeals officer that he intended to audio
record his hearing and bring a court reporter to make a
stenographic recording of the hearing. On August 15, 2002, the
Appeals officer sent petitioner a letter informing him that as of
May 2, 2002, the Appeals Office no longer allowed taxpayers to
make audio or stenographic recordings of hearings. The Appeals
officer also sent him a copy of a Memorandum for All Appeals Area
Directors dated May 2, 2002, from the Acting Chief of the Office
of Appeals outlining the new policy. See Keene v. Commissioner,
121 T.C. 8, 12 (2003), for the text of the memorandum.
On September 9, 2002, petitioner’s hearing was held.
Petitioner was not permitted to audio record or stenograph the
hearing. At the hearing, the Appeals officer provided petitioner
with a copy of Form 4340, Certificate of Assessments, Payments,
and Other Specified Matters, for his 1997 year. The Appeals
officer also explained to petitioner that he could offer
collection alternatives at his hearing, which would be considered
only if he was current in his filing requirements for years other
than 1997. On September 10, 2002, the Appeals officer sent
petitioner a letter addressing some issues raised during the
hearing and a copy of Delegation Order No. 196 (Rev. 4), which
delegates the authority to sign notices of Federal tax liens to
IRS Compliance Managers. Petitioner replied in a letter dated
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