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delegation by the Secretary to the Commissioner, and a
redelegation by the Commissioner to the delegated officers and
employees.” Hughes v. United States, 953 F.2d 531, 536 (9th Cir.
1992) (citing section 301.7701-9, Proced. & Admin. Regs.).
The Internal Revenue Manual, pt. 21.2.3.4.2.1 (Oct. 1,
2002), provides that preparation of Form 4340 is “limited to a
few authorized persons only. These employees are in the
Compliance and Accounting Branch functions.” The person signing
the Form 4340 that related to petitioner’s 1997 tax liability was
the accounting branch chief of respondent’s local district
office, Kathleen R. Bushnell. Without contradictory evidence, we
have no reason to doubt that Ms. Bushnell was authorized to sign
the Form 4340.
Appeals Officer Kelly stated at the section 6320 hearing
(and we have no reason to believe otherwise) that he verified
that all statutory, regulatory, and administrative requirements
for the collection action involved herein (i.e., the filing of a
Federal tax lien) had been met, as required by section
6330(c)(1). Appeals Officer Kelly noted that (1) petitioner
failed to file a proper 1997 Federal income tax return; (2) a
statutory notice of deficiency was issued; (3) petitioner failed
to contest respondent’s determinations as set forth in the notice
of deficiency; (4) an assessment of the deficiency was made; (5)
proper balance due notices were issued; (6) when petitioner
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