Brenda H. Robinson - Page 8




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          because:  (1) The notices of deficiency are invalid; (2) the                
          persons sending the notices of levy and determination did not               
          have authority to do so; (3) respondent did not produce                     
          delegation orders showing that authority; (4) respondent did not            
          produce verification from the Secretary that requirements of                
          applicable law and administrative procedure have been met; and              
          (5) respondent did not give petitioner copies of the law which              
          makes her liable for income taxes.                                          
               We rejected petitioner’s first and second arguments in                 
          paragraph A, above.  We reject her third argument because                   
          internal revenue laws and regulations do not require the Appeals            
          officer to give the taxpayer a copy of the delegation of                    
          authority from the Secretary to the person (other than the                  
          Secretary) who signed the verification required under section               
          6330(c)(1).  Nestor v. Commissioner, 118 T.C. 162, 166-167                  
          (2002).  We reject her fourth argument because section 6330(c)(1)           
          does not require the Appeals officer to give the taxpayer a copy            
          of the verification that the requirements of any applicable law             
          or administrative procedure have been met.  Id. at 166.  Section            
          301.6330-1(e)(1), Proced. & Admin. Regs., requires that the                 
          Appeals officer obtain verification before issuing the                      
          determination, not that he or she provide it to the taxpayer.  In           
          any event, the Appeals officer gave petitioner copies of the                
          certified transcripts of account for 1993 and 1994.  We reject              







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