127 T.C. No. 16
UNITED STATES TAX COURT
DOMINIC CALAFATI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17529-03L. Filed December 26, 2006.
P filed a motion for summary judgment in this sec.
6330, I.R.C., proceeding. In his petition, P disputed
R’s notice of determination concerning collection
action with respect to his 1998 tax liability on the
ground that he was not permitted by the IRS Appeals
Office to make an audio recording of his sec. 6330,
I.R.C., telephone hearing, in violation of sec.
7521(a)(1), I.R.C. P informed R before the telephone
hearing that he intended to audio record the hearing
pursuant to sec. 7521(a)(1), I.R.C., and Keene v.
Commissioner, 121 T.C. 8 (2003). R refused to permit P
to audio record the telephone hearing but did not
inform him of R’s post-Keene policy that a taxpayer
could audio record a face-to-face hearing. The parties
agreed to consider the scheduled telephone hearing
convened and then terminated, with no substantive
issues discussed, because P was not allowed to audio
record the hearing.
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