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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Petitioner argues that the notice was withdrawn “because it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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