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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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