Keene v. Comm'r
United States Tax Court
P filed a petition for levy action under sec. 6330(d), I.R.C., disputing R's notice of determination concerning collection action with respect to his 1991 tax liability on the ground that he was not permitted by the IRS Appeals Office to make an audio recording of his sec. 6330 hearing, in violation of sec. 7521(a)(1), I.R.C. Subsequently, P filed an amended petition again asserting his claimed right to audio record such hearing.
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P filed a petition for levy action under sec. 6330(d), I.R.C., disputing R's notice of determination concerning collection action with respect to his 1991 tax liability on the ground that he was not permitted by the IRS Appeals Office to make an audio recording of his sec. 6330 hearing, in violation of sec. 7521(a)(1), I.R.C. Subsequently, P filed an amended petition again asserting his claimed right to audio record such hearing. P had previously submitted documents to R in his request for a collection due process hearing that asserted several frivolous and groundless arguments. R informed P…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
This matter is before the Court on respondent’s motion for summary judgment, filed pursuant to Rule 121. The only issue raised by the parties is whether, pursuant to the provisions of section 7521(a)(1), petitioner is entitled to audio record his section 6330 hearing…
2Cases cited11 opinions
- 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
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
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3Cited by71 opinions
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- Cox v. Comm'rUnited States Tax Court · 2006
- Burke v. Comm'rUnited States Tax Court · 2005
- Taylor v. Comm'rUnited States Tax Court · 2004
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