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balance due is a notice and demand for payment under section
6303(a). Craig v. Commissioner, 119 T.C. 252, 262-263 (2002).
4. Whether Petitioner Had Verification That Requirements
of Applicable Law and Administrative Procedures Had
Been Met and That Respondent’s Employees Had Authority
From the Secretary To Collect Tax
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, supra at 166-167. 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 301.6320-1(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, Parker gave petitioner a copy of the certified
transcripts of account for 1995 and 1996.
5. Whether This Case Should Be Remanded to Appeals for a
Face-to-Face Hearing
Petitioner contends that he was entitled to a face-to-face
hearing. We disagree. In Lunsford v. Commissioner, 117 T.C.
183, 189 (2001), the Court declined to remand the case to the
Appeals Office for a hearing because the taxpayer could not
prevail on any of the issues he had raised in the proceeding. As
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