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deficiency petitioner received was signed by the Service Center
Director in Atlanta. Therefore, we conclude that petitioner did
receive a valid notice of deficiency for 1997.
Petitioner also contends that the final notice of intent to
levy and the notice of Federal tax lien filing that he received
are invalid because they were not signed by the Secretary as
required by sections 6330(a)(1) and 6320(a)(1). We disagree.
For purposes of sections 6330(a) and 6320(a), the Secretary
delegated the authority to issue notices of levy or lien to
certain IRS employees. Secs. 7701(a)(11)(B) and (12)(A)(i),
7803(a)(2); see also secs. 301.6330-1(a)(1), 301.6320-1(a)(1),
Proced. & Admin. Regs. The authority to levy on taxpayers’
property was delegated to the “Automated Collection Branch
Chiefs” in Delegation Order No. 191 (Rev. 2), effective Oct. 1,
1999. Wilson v. Commissioner, T.C. Memo. 2002-242. Consistent
with this delegation of authority, the final notice of intent to
levy in this case, which was executed by the chief of the
Automated Collection Branch in Kansas City, Missouri, was valid.
See Wilson v. Commissioner, supra. The authority to sign notices
of Federal tax lien was delegated to the compliance managers
responsible for collection matters in Delegation Order No. 196
(Rev. 4), effective Oct. 4, 2000. Hathaway v. Commissioner, T.C.
Memo. 2004-15. Petitioner’s Notice of Federal Tax Lien Filing
and Your Right to a Hearing Under Section 6320 was executed by
the Compliance Technical Support Territory Manager for Kansas
City, Missouri, and was valid.
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