Calafati v. Comm'r
United States Tax Court
P filed a motion for summary judgment in this sec. 6330, I.R.C., proceeding. In his petition, P disputed R's notice of determination concerning collection action with respect to his 1998 tax liability on the ground that he was not permitted by the IRS Appeals Office to make an audio recording of his sec. 6330, I.R.C., telephone hearing, in violation of sec. 7521(a)(1), I.R.C.
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P filed a motion for summary judgment in this sec. 6330, I.R.C., proceeding. In his petition, P disputed R's notice of determination concerning collection action with respect to his 1998 tax liability on the ground that he was not permitted by the IRS Appeals Office to make an audio recording of his sec. 6330, I.R.C., telephone hearing, in violation of sec. 7521(a)(1), I.R.C. P informed R before the telephone hearing that he intended to audio record the hearing pursuant to sec. 7521(a)(1), I.R.C., and Keene v. Commissioner, 121 T.C. 8 (2003). R refused to permit P to audio record the…
1Opinion of the Court
DOMINIC CALAFATI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Calafati v. Comm'r
No. 17529-03L
United States Tax Court
127 T.C. 219; 2006 U.S. Tax Ct. LEXIS 37; 127 T.C. No. 16;
December 26, 2006, Filed
The court granted the taxpayer's motion for summary judgment, in part, and remanded the taxpayer's case to the Internal Revenue Service Office of Appeals for further proceedings. The court denied the taxpayer's motion to the extent that it asserted a right to audio record a 26 U.S.C.S. § 6330 telephone hearing.
P filed a motion for summary judgment in this sec. 6330,
I.R.C., proceeding.…
2Cases cited22 opinions
- Duncan v. WalkerSupreme Court of the United States · 2001
- Muscarello v. United StatesSupreme Court of the United States · 1998
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Weinberger v. Hynson, Westcott & Dunning, Inc.Supreme Court of the United States · 1973
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