- 10 -
382, 399-400 (1965), affd. 373 F.2d 45 (10th Cir. 1967); Urban v.
Commissioner, T.C. Memo. 1991-220, affd. per curiam 964 F.2d 888
(9th Cir. 1992). Section 6212 requires that the notice be sent.
Even if the signature block does not comply with the
Internal Revenue Manual, the rules of the Manual have been held
to be merely directory and not mandatory.9 See Urban v.
Commissioner, 964 F.2d 888, 890 (9th Cir. 1992). The
Commissioner sent petitioner the notices of deficiency for the
taxable years in issue, and petitioner confirmed his receipt of
them. Thus, even if the notices of deficiency were signed by
using an overprint or a machine-imprinting process, as petitioner
contends, rather than hand-signed, they would still be valid
notices of deficiency. Likewise, the Forms 4549 accompanying the
notices of deficiency are valid for the purpose of informing
petitioner of his income tax examination changes. They need not
be signed.
V. Petitioner’s Taxable Income
Petitioner stipulated the receipt of the income underlying
the notices of deficiency and did not introduce any evidence to
establish that he was entitled to any deductions or credits not
9 The Internal Revenue Manual was designed to aid in the
internal administration of the Internal Revenue Service, not for
the protection of taxpayers; thus, it is not binding upon and
confers no rights to taxpayers. Fargo v. Commissioner, __ F.3d__
n.9 (9th Cir., May 9, 2006), affg. T.C. Memo. 2004-13; United
States v. Mapp, 561 F.2d 685, 690 (7th Cir. 1977); United States
v. Lockyer, 448 F.2d 417, 421 (10th Cir 1971).
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