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vice Center Examination Branch in Ogden, Utah, and I
have no way of knowing whether he has been delegated by
the Secretary to send out of [sic] such notices on the
Secretary’s behalf. So, before I do anything at all
with respect to your “Notice,” I would have to see a
Delegation Order from the Secretary of the Treasury
delegating to Dennis L. Paiz the authority to send out
Deficiency Notices.
In addition, I would also like you to send me (or
identify for me) the legislative regulations that you
claim implement Code Sections 6212 and 6213. I have
also attached an excerpt from the IRS Procedures Manual
* * * which points out that the IRS is required to
“make available to all taxpayers comprehensive, accu-
rate, and timely information on the requirements of tax
law and regulations.” So, pursuant to this provision
from your Procedures Manual, I am asking that you
identify (make available) for me the legislative regu-
lations that you claim implement both Code Sections
6212 and 6213 - since I have not been able to locate
them.
Without your furnishing me with these documents and
information, I will be unable to “ascertain” * * *
whether the individual who sent me the Deficiency
Notice was authorized to do so, and whether I am le-
gally required to take any notice of it. * * *
On August 7, 2000, respondent assessed petitioner’s tax, as
well as any penalties and interest as provided by law, for his
taxable year 1998. (We shall refer to those assessed amounts, as
well as interest as provided by law accrued after August 7, 2000,
as petitioner’s unpaid liability for 1998.)
On August 7, 2000, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid liability for
1998.
On August 6, 2001, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
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