Dominic Calafati v. Commissioner

127 T.C. No. 16

UNITED STATES TAX COURT DOMINIC CALAFATI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17529-03L. Filed December 26, 2006. 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…