contents of Form 4549). 16 . Perez further argues that Form 4549 requires the explicit approval of the IRS’s District Director in order for it to be effective. He derives this argument from the last line of Form 4549, which states that the taxpayer understands "that this report is subject to acceptance by the District Director.” In this case, the Form 4549 was signed only by the IRS examiner. We reject Perez’s contention that an IRS examiner is not a duly authorized agent of the district director capable of accepting a Form 4549. In re Barry, 48 B.R. at 603 ("A revenue agent is a delegate of the district director authorized to accept waivers. His signature is sufficient 'acceptance' of this [IRS Form 4549] waiver.”). Cf. Holbrook v. United States, 284 F.2d 747 (9th Cir.1960) (<HOLDING>). 17 . See 26 U.S.C. §§ 6212-6213. 18 .
holding that the point on appeal and the objection in the trial court must be the same in order for it to be preserved for appeal holding that it is not holding that it is not necessary for the irs commissioner to personally consent to a taxpayer waiver in order for it to be effective holding officer personally liable because he agreed to personally guarantee payment on an account holding that persons knowledge of his right to refuse a consent to search is a factor but not a necessary prerequisite to demonstrating a voluntary consent