On appeal, Palmer asserts that that his notice of deficiency was issued by an agent who lacked authority to implement the Internal Revenue Code.

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We define an agency relationship as a contract under which one or more persons (the principal(s)) engage another person (the agent) to perform some service on their behalf which involves delegating some decision making authority to the agent.

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Where an institutional customer has delegated decisionmaking authority to an agent, such as an investment adviser or a bank trust department, these factors shall be applied to the agent.

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