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May 1995 and transferred to California, as he demanded. Had
respondent advised petitioner again that his request for
delay/transfer had been finally denied, petitioner’s own
statements indicate that he would not have participated in the
audit and that the same events would have happened.
Fourth, petitioner contends that the process by which IRS
customer service officers are trained constitutes a “ministerial
error” that resulted in the delay in paying his deficiency. “My
claim is that the process and procedure of recruiting, hiring and
training IRS customer service representatives is what was the
cause of the error or delay (a ministerial error not a managerial
error.” We disagree. The process of recruiting, hiring, and
training IRS customer service representatives is attributable to
respondent’s general administrative decisions, and not to a
ministerial act, and therefore no relief is available to
petitioner on account of these decisions.
Fifth, petitioner argues that respondent committed a
ministerial error or delay by failing to audit petitioner’s
records on-the-spot when he walked into respondent’s Oakland
office in September 1995, without an appointment, and demanded an
immediate audit of his returns. Petitioner has, of course, cited
no authority for his position that respondent is required to
perform audits-on-demand for taxpayers who walk in to
respondent’s offices, and we are aware of no such requirement.
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