Larry A. Michael - Page 12




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          that the notice of deficiency issued to him was invalid because,            
          he asserts, it was not signed by the Secretary or somebody                  
          delegated by the Secretary.  We consider this argument frivolous.           
          The notice of deficiency was signed by the Director of an                   
          Internal Revenue Service Center.  The Secretary or his delegate             
          is authorized by statute to issue notices of deficiency, secs.              
          6212(a), 7701(a)(11)(B) and (12)(A)(i), and it is well                      
          established that the Director of an Internal Revenue Service                
          Center is an authorized delegate, e.g., Hughes v. United States,            
          953 F.2d 531, 536 (9th Cir. 1992); Nestor v. Commissioner, 118              
          T.C. 162 (2002); Weishan v. Commissioner, T.C. Memo. 2002-88.               
               Petitioner argues that the Appeals officer failed to obtain            
          verification from the Secretary that the requirements of all                
          applicable laws and administrative procedures were met as                   
          required by section 6330(c)(1).  We disagree.  First, section               
          6330(c)(1) does not require the Commissioner to rely upon a                 
          particular document (e.g., the summary record itself rather than            
          transcripts of account) to satisfy this verification requirement.           
          Kuglin v. Commissioner, T.C. Memo. 2002-51; see also Weishan v.             
          Commissioner, supra.  Second, the Appeals officer is not required           
          to give the taxpayer a copy of the verification that the                    
          requirements of any applicable law or administrative procedure              
          have been met.  Sec. 6330(c)(1); sec. 301.6330-1(e)(1), Proced. &           
          Admin. Regs.; see also Nestor v. Commissioner, supra.  More                 






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