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reference to the difference between the manner in which revenue
officers operated in the 19th century and the way they operate
today:
There was virtually no Washington bureaucracy created
by the Act of July 1, 1862, ch. 119, 12 Stat. 432, the
statute to which the present Internal Revenue Service
can be traced. Researchers report that during the
Civil War 85 percent of the operations of the Bureau of
Internal Revenue were carried out in the field--
“including the assessing and collection of taxes, the
handling of appeals, and punishment for frauds”-- and
this balance of responsibility was not generally upset
until the 20th century. L. Schmeckebier & F. Eble, The
Bureau of Internal Revenue 8, 40-43 (1923). Agents had
the power to enter any home or business establishment
to look for taxable property and examine books of
accounts. Information was collected and processed in
the field. It is, therefore, not surprising to find
that congressional comments during this period focused
on potential abuses by agents in the field and not on
breaches of confidentiality by a Washington-based
bureaucracy. [Id. at 297 n.23.]
Petitioner’s counsel quotes this footnote as support for her
argument that the Internal Revenue Service is not a governmental
agency. We are unable to discern how the footnote or the
Chrysler Corp. opinion in any way supports petitioner’s argument
that the Internal Revenue Service is not an agency of the United
States.
Petitioner next claims that in Diversified Metal Prods.,
Inc. v. T-Bow Co. Trust, 78 AFTR 2d 5830, 96-2 USTC par. 50,437
(D. Idaho 1996), the United States admitted that the Internal
Revenue Service was not an agency, and the court based its
decision on that admission. The issue in Diversified Metal was
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