Dominic Calafati - Page 4

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          process.”  On July 8, 2003, after petitioner requested his                  
          hearing, we released our Opinion in Keene v. Commissioner, 121              
          T.C. 8 (2003).  In Keene, we held that a taxpayer was entitled to           
          audio record a face-to-face section 6330 hearing under section              
               By letter dated July 28, 2003, Appeals Officer Paula Stanton           
          (the Appeals officer) informed petitioner that his section 6330             
          hearing was scheduled to take place on August 12, 2003, at the              
          Service’s Philadelphia, Pennsylvania, Appeals Office.                       
          Petitioner’s representative, Albert Wagner (Mr. Wagner),                    
          telephoned the Appeals officer to reschedule the hearing for                
          August 18, 2003, and to request that the hearing be conducted by            
          telephone.  Mr. Wagner also advised the Appeals officer that he             
          intended to audio record the telephone hearing.  The Appeals                
          officer informed Mr. Wagner that audio recording would not be               
          permitted.  In response, Mr. Wagner stated that he still wanted             
          to proceed with the telephone hearing.                                      
               On or around August 11, 2003, several days after the                   
          telephone conversation with Mr. Wagner, the Appeals officer                 
          received a facsimile dated August 7, 2003, from Mr. Wagner that             
          confirmed Mr. Wagner’s desire to participate in the August 18               
          telephone hearing and reiterated his intent to audio record the             
          hearing “pursuant to IRC �7521(a)(1)” and “the recent Tax Court             
          decision, * * * Keene v Commissioner”.  The Appeals officer did             

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