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because: (1) The notices of deficiency are invalid; (2) the
persons sending the notices of levy and determination did not
have authority to do so; (3) respondent did not produce
delegation orders showing that authority; (4) respondent did not
produce verification from the Secretary that requirements of
applicable law and administrative procedure have been met; and
(5) respondent did not give petitioner copies of the law which
makes her liable for income taxes.
We rejected petitioner’s first and second arguments in
paragraph A, above. We reject her third argument because
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, 118 T.C. 162, 166-167
(2002). We reject her fourth argument because 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
301.6330-1(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, the Appeals officer gave petitioner copies of the
certified transcripts of account for 1993 and 1994. We reject
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