Dominic Calafati - Page 1

                                   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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