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
OPINION
Marvel, Judge:
This matter is before the Court on petitioner’s motion for summary judgment filed pursuant to Rule 121.1
Background
This is an appeal from respondent’s determination upholding the proposed use of a levy to collect petitioner’s unpaid Federal income tax liability for 1998. The only issues petitioner raises are whether, pursuant to the provisions of section 7521(a)(1), petitioner was entitled to audio record his section 6330 telephone hearing with the Internal Revenue Service Appeals Office (the Appeals Office) and, alternatively, whether petitioner was entitled to be…
2Cases cited20 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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3Cited by8 opinions
- United States v. LouisianaDistrict Court, M.D. Louisiana · 2016
- Rodney P. Walker v. CommissionerUnited States Tax Court · 2018
- Fleming v. Comm'rUnited States Tax Court · 2017
- Calafati v. Comm'rUnited States Tax Court · 2006
- Caudle v. Comm'rUnited States Tax Court · 2015
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