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(holding that section 6212 does not require that a notice of
deficiency be signed).
Although the provisions cited above reflect the prominent
role that Appeals officers are assigned in collection review
cases, we reject the premise underlying petitioner’s position;
i.e., that only the Appeals officer who conducted the
administrative hearing may sign a notice of determination. To
the extent that the Commissioner and/or the Office of Chief
Appeals has decided that notices of determination under sections
6320 and 6330 should be reviewed, approved, and signed by Appeals
Team Managers (as was the case here), such decision is not in
derogation of section 6330 but rather constitutes an internal
agency matter that we are not inclined to question.5
Consistent with the preceding discussion, we conclude that
the Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330, dated April 11, 2002, upon which this
case is based, is valid. Accordingly, we shall deny petitioner’s
5 Indeed, by interposing a layer of review between the
determination by an Appeals officer and the issuance of a notice
of determination, the taxpayer protections afforded by sec. 6330
are strengthened, which is consistent with the enactment of that
section by the Internal Revenue Service Restructuring and Reform
Act of 1998, Pub. L. 105-206, sec. 3401(b), 112 Stat. 685. See
S. Rept. 105-174, at 67-69 (1998), 1998-3 C.B. 537, 603-605; H.
Conf. Rept. 105-599, at 263-266 (1998), 1998-3 C.B. 755, 1017-
1020; cf. sec. 7122(d)(1) (requiring procedures for an
independent administrative review of any rejection of a proposed
offer-in-compromise or installment agreement made by a taxpayer
before such rejection is communicated to the taxpayer).
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