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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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