John O. Green - Page 8




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          to, among others, “Wage & Investment * * * Directors: * * * Field           
          Compliance Services”.  Lynne Walsh, Field Director, Compliance              
          Services, Brookhaven Service Center, was a proper delegate of the           
          Secretary to issue (sign) the notice.  Furthermore, there is no             
          requirement that a notice of deficiency be signed.  E.g., Pendola           
          v. Commissioner, 50 T.C. 509, 513-514 (1968).                               
               E.  Withdrawal of the Notice                                           
               Petitioner argues that the notice was withdrawn “because it            
          was processed in error”.  To support that claim, petitioner asks            
          the Court to examine entries in a transcript of his individual              
          master file (the transcript or the IMF, as appropriate) that he             
          states he obtained from the IRS pursuant to a Freedom of                    
          Information Act request.  Although respondent describes the                 
          transcript as an unauthenticated document that petitioner failed            
          to introduce into evidence, he meets petitioner’s argument with             
          respect to the transcript head on.  We assume, therefore, that              
          respondent accepts the authenticity of the transcript and has               
          waived his argument that petitioner did not introduce it into               
          evidence.                                                                   
               An IMF is a file maintained by the IRS that contains coded             
          information relevant to the tax status of an individual.  United            
          States v. Buford, 889 F.2d 1406, 1407 n.1 (5th Cir. 1989).  In              
          order to decipher the coded information, a code book is needed.             
          Id. at 1407.  There appear to be two relevant entries on the                







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