- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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