Michael Cipolla - Page 9

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          at the hearing conducted under section 6330.  Sec. 6330(c)(2)(B).           
          Nonetheless, he argues that the notice of deficiency was not                
          signed by someone in authority and was invalid.  This position is           
          frivolous and groundless.  Nestor v. Commissioner, 118 T.C. 162,            
          165-166 (2002) (noting that Directors of Service Centers have               
          been delegated the authority to issue notices of deficiency);               
          Koenig v. Commissioner, T.C. Memo. 2003-40 n.4; see Schmith v.              
          Commissioner, T.C. Memo. 2002-252 (taxpayer’s denial of receiving           
          “valid” notice of deficiency did not mean the taxpayer failed to            
          receive notice of deficiency).                                              
          Verification Requirement                                                    
               We likewise reject petitioner’s argument 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).  The record shows               
          that the Appeals officer obtained and reviewed a literal                    
          transcript of petitioner’s account for 1997, and that she                   
          provided this transcript of account to petitioner at his Appeals            
          hearing.  The information in this transcript is also contained in           
          the Form 4340, Certificate of Assessments, Payments and Other               
          Specified Matters, that the parties stipulated in evidence.                 
          Section 6330(c)(1) does not require the Commissioner to rely on a           
          particular document (e.g., the summary record itself rather than            
          a transcript of account) to satisfy the verification requirement            






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