Kevin Thompson - Page 8

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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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