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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).
The Appeals officer did not give petitioner a copy of the
record of assessment at or before the hearing as petitioner had
requested. Respondent gave petitioner copies of the Forms 4340
prior to the trial in this case. The Forms 4340 that respondent
gave petitioner before trial showed that the amounts at issue
were properly assessed, and petitioner did not show at trial any
irregularity in the assessment procedure that would raise a
question about the validity of the assessments. Requiring the
Appeals officer to provide petitioner with a second copy of
petitioner’s Forms 4340 at this time would delay disposition of
this case. Petitioner was not prejudiced in any way by the fact
that he first received copies of those records after the section
6330 hearing. Thus, whether or not the second sentence of
section 6203 is an “applicable law or administrative procedure”
referred to in section 6330(c)(1), it is clear that no bona fide
interest would be served by further delaying the collection of
petitioner’s tax liability for 1992-97.
Petitioner contends that the notice of intent to levy
improperly failed to identify the Code sections which establish
his alleged tax liability. He contends that the assessment of
tax was improper because he filed tax returns for 1990-97 which
showed that he owed no income taxes for those years. He also
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Last modified: May 25, 2011