§3421

(b) The Notice of Federal Tax Lien which forms the basis of this case is invalid, as the Revenue Officer whose name appears on the Notice of Federal Tax Lien was not authorized to file nominee Notices of Federal Tax Lien without the written approval of his direct supervisor issued pursuant to §3421 of the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA ‘98).

venue Manual (IRM) requires, e.g., managerial and other approval for “special condition” NFTLs, see IRM 5.12.7.6.5 (Apr. 22, 2019), but no such approval is required for NFTLs in general, IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, § 3421, 112 Stat. 685, 758; IRM 5.19.4.5.3.4 (Jan. 1, 2015). Petitioners’ NFTL does not fall within the “special condition” category, so managerial approval was not required. Accordingly, because administrative procedures were properly followed, it w

implement an enhanced supervisoryreview process for liens, levies, and seizures. That provision was made effective generally for collection actions commenced after the date ofenactment. IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, sec. 3421, 112 Stat. at 758. - 39 - chip." S. Rept. No. 105-174, supra at 65, 1998-3 C.B. at 601. These stated concerns would seem to be addressed by our redetermination in this case: As discussed in detail below, we conclude that imposition ofthe 20

The RRA'98 Act Section 3421, which-requires that IRS employees and managers follow a review and approval process for a lien, was followed .