193786P.pdf   06/08/2021  Jason Stewart  v.  CIR
   U.S. Court of Appeals Case No:  19-3786
   United States Tax Court   
   [PUBLISHED] [Stras, Author, with Shepherd and Kobes, Circuit Judges] 
   Civil case - Federal Tax. Taxpayers were not entitled to a new hearing 
   because a revenue officer included notes and correspondence about a 
   meeting with their attorney in the official file that was later made 
   available to the settlement officer who reviewed the case; while such 
   statements are generally prohibited under the IRS's administrative-file 
   rule, they can be included if they were contemporaneous and are pertinent 
   to the revenue officer's consideration of the case; the materials fell 
   within this exception, and their inclusion in the file did not compel a 
   new hearing.