- 8 - (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).Page: Previous 1 2 3 4 5 6 7 8 9 Next
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