Dominic Calafati - Page 10

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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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