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Third, and most significantly, we reject petitioner’s
position because, as the general and ordinary definitions of “in-
person” suggest, a section 6330 hearing that takes place by
telephone is not a hearing where the parties, or their
representatives, are within each other’s bodily presence, or “in-
person”. To hold that a section 6330 telephone hearing is an
“in-person interview” for purposes of section 7521(a)(1),
therefore, would be contrary to well-settled rules of statutory
construction because it would render the words “in-person” in
section 7521 meaningless. Duncan v. Walker, 533 U.S. 167, 174
(2001) (statute ought to be construed so that no clause,
sentence, or word is rendered superfluous, void, or
insignificant); Weinberger v. Hynson, Westcott & Dunning, Inc.,
412 U.S. 609, 633 (1973) (“all parts of a statute, if at all
possible, are to be given effect”). For these reasons, we hold
that section 7521(a)(1) does not entitle petitioner to make an
audio recording of his section 6330 telephone hearing.3
3We recognize that several of the reasons we enumerated in
Keene to support our holding that sec. 7521(a)(1) entitles a
taxpayer to audio record his sec. 6330 face-to-face hearing would
apply equally to a taxpayer who participates in a sec. 6330
telephone hearing. For example, a sec. 6330 telephone hearing is
just as integral a part of the tax collection process as a face-
to-face hearing, and a transcript of a section 6330 telephone
hearing would facilitate judicial review of a determination made
by the Appeals Office with respect to a proposed levy by the
Commissioner just as a transcript of a face-to-face hearing
would. See Keene v. Commissioner, 121 T.C. 8, 17-18 (2003).
However, sec. 7521(a)(1) specifically limits a taxpayer’s right
(continued...)
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