- 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011