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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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