- 8 - 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 rejectPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011