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amount of petitioner’s underlying 1997 tax liability is not a
relevant issue to be addressed at the section 6320 hearing. See
Sego v. Commissioner, supra at 609.
Petitioner was afforded an opportunity at the section 6320
hearing to raise all relevant issues as set forth in section
6330(c)(2)(A), including offers of collection alternatives. He
failed to take advantage of that opportunity.4
Petitioner claims that there was an irregularity in the Form
4340 sent to him. As best we can understand petitioner’s
position, he complains that the Form 4340 was improperly signed
by Kathleen R. Bushnell, Accounting Branch Chief. This argument
is groundless.
Section 6301 provides that the Secretary has the power to
collect taxes. That power can be delegated to IRS District
Directors and in turn redelegated to local-level officials. See
sec. 301.6301-1, Proced. & Admin. Regs.; Delegation Order No. 198
(Rev. 5), Sept. 7, 2001. “The delegation of authority down the
chain of command, from the Secretary to the Commissioner of
Internal Revenue, to local IRS employees constitutes a valid
4At trial, petitioner appeared to be willing to discuss
compromising his 1997 tax liability. He did not, however, make
any offer. Moreover, because petitioner failed to file a proper
tax return for 1998, 1999, 2000, or 2001 and appeared unwilling
to do so, the IRS (pursuant to its stated policy) would be
precluded from considering any offer in compromise made by
petitioner with respect to his 1997 unpaid tax liability. In any
event, if petitioner seriously wanted to propose a collection
alternative, he should have done so at the sec. 6320 hearing.
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