Dominic Calafati - Page 11

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               (1979) defines the term as “a formal consultation” or                  
               “a meeting at which information is obtained”.                          
          Id. at 15.                                                                  
               Applying this analysis, we concluded that a section 6330               
          hearing has the “characteristics of an ‘interview’” because the             
          “meeting between the taxpayer and the Appeals officer is face-to-           
          face, private, arranged for the discussion of specific matters,             
          and formal in the sense that it is prescribed by law.”  Id. at              
          16, 17 (emphasis added).  We also concluded that                            
               As the general and ordinary definitions of “interview”                 
               suggest, we think the exchange of information that                     
               occurs between a taxpayer and an Appeals officer during                
               an administrative hearing conducted under section 6330                 
               constitutes an “in-person interview” within the meaning                
               of that term as used in section 7521(a)(1).                            
          Id. at 16.                                                                  
          Because we were also persuaded that (1) a section 6330 hearing              
          “is an integral part of the tax collection process and therefore            
          relates to the ‘collection of any tax’ within the meaning of                
          section 7521(a)(1)”, (2) “denying the taxpayer’s right to audio             
          record would serve to undermine the safeguards in IRS collection            
          actions that Congress created in section 6330”, (3) the                     
          Commissioner’s interpretation of section 7521 would have the                
          anomalous result of allowing audio recording of interviews that             
          we typically do not review but not allowing recording of                    
          proceedings we are statutorily charged with reviewing, and (4)              
          having a transcript of the section 6330 hearing would facilitate            

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