- 11 -
Memo. 2002-86, affd. 70 Fed. Appx. 971 (9th Cir. 2003); Duffield
v. Commissioner, T.C. Memo. 2002-53; Kuglin v. Commissioner, T.C.
Memo. 2002-51.
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcript of account relied on by Ms. Cahill. See Davis v.
Commissioner, 115 T.C. 35, 41 (2000); Mann v. Commissioner, T.C.
Memo. 2002-48. Accordingly, we conclude that there is no
question that the Appeals officer satisfied the verification
requirement of section 6330(c)(1).
4. Delegation Order
Petitioner's allegations regarding the authority of the
individual issuing the notice of intent to levy are meritless.
The Secretary or his delegate (including the Commissioner) may
issue collection notices, and authority to issue notices
regarding liens and to levy upon property has in turn been
delegated to specified collection and compliance personnel.
Secs. 6320(a), 6330(a), 7701(a)(11)(B) and 12(A)(i), 7803(a)(2);
secs. 301.6320-1(a)(1), 301.6330-1(a)(1), Proced. & Admin. Regs.;
Delegation Order No. 191 (Rev. 3, June 11, 2001); Delegation
Order No. 196 (Rev. 4, Oct. 4, 2000); see also Craig v.
Commissioner, 119 T.C. 252, 263 (2002); Everman v. Commissioner,
T.C. Memo. 2003-137.
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