---
kind: "section"
citation: "26 U.S.C. § 7521"
title: "26"
title_heading: "Internal Revenue Code"
number: "7521"
heading: "Procedures involving taxpayer interviews"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/7521"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 77 — Miscellaneous Provisions"
---

# §7521. Procedures involving taxpayer interviews

- (a) **Recording of interviews—**
  - (1) **Recording by taxpayer—** Any officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service in connection with any in-[person](/usc/26/7701.md?p=a-1) interview with any [taxpayer](/usc/26/7701.md?p=a-14) relating to the determination or collection of any tax shall, upon advance request of such [taxpayer](/usc/26/7701.md?p=a-14), allow the [taxpayer](/usc/26/7701.md?p=a-14) to make an audio recording of such interview at the [taxpayer](/usc/26/7701.md?p=a-14)’s own expense and with the [taxpayer](/usc/26/7701.md?p=a-14)’s own equipment.
  - (2) **Recording by IRS officer or employee—** An officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service may record any interview described in [paragraph (1)](#a-1) if such officer or [employee](/usc/26/7701.md?p=a-20)—
    - (A) informs the [taxpayer](/usc/26/7701.md?p=a-14) of such recording prior to the interview, and
    - (B) upon request of the [taxpayer](/usc/26/7701.md?p=a-14), provides the [taxpayer](/usc/26/7701.md?p=a-14) with a transcript or copy of such recording but only if the [taxpayer](/usc/26/7701.md?p=a-14) provides reimbursement for the cost of the transcription and reproduction of such transcript or copy.
- (b) **Safeguards—**
  - (1) **Explanations of processes—** An officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service shall before or at an initial interview provide to the [taxpayer](/usc/26/7701.md?p=a-14)—
    - (A) in the case of an in-[person](/usc/26/7701.md?p=a-1) interview with the [taxpayer](/usc/26/7701.md?p=a-14) relating to the determination of any tax, an explanation of the audit process and the [taxpayer](/usc/26/7701.md?p=a-14)’s rights under such process, or
    - (B) in the case of an in-[person](/usc/26/7701.md?p=a-1) interview with the [taxpayer](/usc/26/7701.md?p=a-14) relating to the collection of any tax, an explanation of the collection process and the [taxpayer](/usc/26/7701.md?p=a-14)’s rights under such process.
  - (2) **Right of consultation—** If the [taxpayer](/usc/26/7701.md?p=a-14) clearly [states](/usc/26/7701.md?p=a-10) to an officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service at any time during any interview (other than an interview initiated by an administrative summons issued under subchapter A of [chapter 78](/usc/26/chstF/ch78.md)) that the [taxpayer](/usc/26/7701.md?p=a-14) wishes to consult with an attorney, certified public accountant, enrolled agent, [enrolled actuary](/usc/26/7701.md?p=a-35), or any other [person](/usc/26/7701.md?p=a-1) permitted to represent the [taxpayer](/usc/26/7701.md?p=a-14) before the Internal Revenue Service, such officer or [employee](/usc/26/7701.md?p=a-20) shall suspend such interview regardless of whether the [taxpayer](/usc/26/7701.md?p=a-14) may have answered one or more questions.
- (c) **Representatives holding power of attorney—** Any attorney, certified public accountant, enrolled agent, [enrolled actuary](/usc/26/7701.md?p=a-35), or any other [person](/usc/26/7701.md?p=a-1) permitted to represent the [taxpayer](/usc/26/7701.md?p=a-14) before the Internal Revenue Service who is not disbarred or suspended from practice before the Internal Revenue Service and who has a written power of attorney executed by the [taxpayer](/usc/26/7701.md?p=a-14) may be authorized by such [taxpayer](/usc/26/7701.md?p=a-14) to represent the [taxpayer](/usc/26/7701.md?p=a-14) in any interview described in [subsection (a)](#a). An officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service may not require a [taxpayer](/usc/26/7701.md?p=a-14) to accompany the representative in the absence of an administrative summons issued to the [taxpayer](/usc/26/7701.md?p=a-14) under subchapter A of chapter 78. Such an officer or [employee](/usc/26/7701.md?p=a-20), with the consent of the immediate supervisor of such officer or [employee](/usc/26/7701.md?p=a-20), may notify the [taxpayer](/usc/26/7701.md?p=a-14) directly that such officer or [employee](/usc/26/7701.md?p=a-20) believes such representative is responsible for unreasonable delay or hindrance of an Internal Revenue Service examination or investigation of the [taxpayer](/usc/26/7701.md?p=a-14).
- (d) **Section not to apply to certain investigations—** This section shall not apply to criminal investigations or investigations relating to the integrity of any officer or [employee](/usc/26/7701.md?p=a-20) of the Internal Revenue Service.

## Source credit

(Added Pub. L. 100–647, title VI, § 6228(a), Nov. 10, 1988, 102 Stat. 3731, § 7520; renumbered § 7521, Pub. L. 101–239, title VII, § 7816(u)(1), Dec. 19, 1989, 103 Stat. 2423.)

## Notes

### Editorial Notes

### Codification

Another section 7521 was renumbered section 7522 of this title.

### Statutory Notes and Related Subsidiaries

### Effective Date

Pub. L. 100–647, title VI, § 6228(d), Nov. 10, 1988, 102 Stat. 3732, provided that: “The amendments made by subsections (a) and (c) [enacting this section] shall apply to interviews conducted on or after the date which is 90 days after the date of the enactment of this Act [Nov. 10, 1988].”