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petitioner was entitled to be informed, before the beginning of
his section 6330 telephone hearing, of respondent’s post-Keene
policy that a face-to-face section 6330 hearing is the only
section 6330 hearing section 7521(a)(1) entitles a taxpayer to
audio record. Petitioner was a resident of Lansdale,
Pennsylvania, when his petition in this case was filed.
Petitioner timely filed his 1998 individual Federal income
tax return. On April 3, 2002, respondent issued a notice of
deficiency (notice) in which he determined that petitioner was
liable for an income tax deficiency of $8,173 and an accuracy-
related penalty, pursuant to section 6662(a), of $1,634.60 for
1998. Petitioner sent a letter dated May 14, 2002, to the
Internal Revenue Service (the Service) appealing the notice, but
he did not petition this Court to review the notice. On August
26, 2002, respondent assessed the deficiency for 1998.
On December 21, 2002, respondent issued a Final Notice of
Intent To Levy and Notice of Your Right to a Hearing with regard
to petitioner’s unpaid tax liability for 1998. On or around
December 30, 2002, petitioner timely submitted a Form 12153,
Request for a Collection Due Process Hearing (section 6330
hearing), in which he contended that “The administrative record
contains egregious errors, and the correction of those errors
will mitigate collection activity. Additionally, several
procedural errors were committed violating administrative due
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