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The taxpayer subsequently filed a petition in this Court in
which he argued that he should have been permitted to record the
face-to-face hearing. Id. The Commissioner contended that the
taxpayer had no right to record the section 6330 proceeding
because a section 6330 hearing was not an “in-person interview”
within the meaning of section 7521(a)(1), section 7521 did not
apply to hearings conducted by the Appeals Office, and a section
6330 hearing was not covered by section 7521 because it was a
voluntary proceeding initiated by a taxpayer and was not an
inquisitorial interview conducted by the Examination or
Collection Division of the type described in section 7521. Id.
at 15-16. We rejected the Commissioner’s contentions.
In our analysis, we acknowledged that section 7521 and its
legislative history neither defined nor explained the term “in-
person interview”. Id. at 14. Consequently, applying well-
established principles of statutory interpretation, our analysis
focused on what constitutes an interview:
The term “interview” is defined by Webster’s Third
New International Dictionary Unabridged 1183-1184
(1993) as:
a meeting face to face: a private conversation; usu: a
formal meeting for consultation: CONFERENCE
Similar definitions appear in other dictionaries. For
example, the American Heritage Dictionary (4th ed.
1970) defines the term “interview” as “a face to face
meeting arranged for the discussion of some matter”;
Webster’s II New Riverside University Dictionary 639
(1984) defines the term as “a formal face-to-face
meeting”; and Webster’s New Collegiate Dictionary 600
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