Charles Raymond Wheeler - Page 10

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          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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