Dominic Calafati - Page 13

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          United States, 524 U.S. 125, 127-132 (1998).  The term “in-                 
          person” is defined by Merriam Webster’s Collegiate Dictionary 867           
          (10th ed. 1997) as “in one’s bodily presence”.  Similar                     
          definitions appear in other dictionaries.  For example, the                 
          Oxford Dictionary and Usage Guide 440 (1995) and the American               
          Heritage Dictionary 978 (1976) define the term as “physically               
          present”, and the New Shorter Oxford English Dictionary, Vol. 2,            
          2171 (1993) defines the term as “with one’s own bodily presence”            
          or “personally”.                                                            
               The ordinary meaning of the term “in person” supports                  
          respondent’s argument that section 7521(a) refers to a face-to-             
          face meeting between the interviewer and the person being                   
          interviewed.  Specifically in the context of section 7521, an               
          “in-person interview” according to respondent contemplates an               
          interview between a taxpayer and/or the taxpayer’s representative           
          and an officer or employee of the Service relating to the                   
          determination or collection of any tax.  See sec. 7521(a).  This            
          interpretation of the language of section 7521(a) is also                   
          buttressed by section 7521(b) and its legislative history.                  
               Section 7521(b)(1) provides that in the case of an “in-                
          person interview with the taxpayer” relating to either the                  
          determination or collection of any tax, the Service is obligated            
          to provide certain information to the taxpayer either before or             
          at the initial interview.  Sec. 7521(b)(1)(A) and (B).  The                 

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