tion also provides that the financial institution may not notify the customer and that the Government must compile an annual tabulation of the occasions in which the section is used.

Section 1114(b) provides for access without prior notice to the customer where delay in obtaining records would create a danger of physical injury to any person, serious property damage or flight to avoid prosecution. Under this provision the 1103(b) certificate must be signed by a supervisory official. Post notice will be provided to the customer under this subsection, and an annual tabulation of the times it is used will be kept.

Section 1115 requires the government to reimburse financial institutions for assembling and furnishing the requested documents. This provision will take effect on October 1, 1979.

Section 1116 places jurisdiction over actions to enforce the title in any U.S.

district court and provides a 3-year statute of limitations for actions brought under the title.

Section 1117(a) provides civil penalties for unauthorized disclosures of $100 for each violation, actual damages, punative damages, and attorney's fees.

Section 1117(b) provides that the Civil Service Commission shall institute proceedings against a government employee if a court finds that the employee may have acted willfully or unintentionally and such actions have led to a successful suit against the Govern

ment.

Section 1117(c) provides that a financial institution will not be liable for disclosures made in good-faith reliance upon an 1103 (b) certificate provided by a government authority.

[56] Section 1117 (d) provides that the remedies and sanctions of this title are the only judicial remedies available for violations of the title.

Section 1118 provides injunctive relief to ensure that the provisions of the title are complied with. This section is intended to give customers the opportunity to petition a court to require government compliance with any of the procedures of the title.

Section 1119 provides that any applicable statute of limitations will be tolled if a customer challenges access to financial records.

Section 1120 provides that information obtained by a Federal grand jury must be returned and actually presented to the grand jury; used only for the purposes of the grand jury, i.e., indictment and prosecution; destroyed or returned to the financial institution if not used for prosecution or sealed; and maintained only in the sealed records of the grand jury unless used as evidence in the crime for which the grand jury issued an indictment.

Delegation Order No. 172 485

Notice List of Countries Requiring Cooperation with an International Boycott 485

468

469

469

470

470

Revenue Procedure 78-15 488 Revenue Procedure 78-16 489 Revenue Procedure 78-17 490 Revenue Procedure 78-18 491 Revenue Procedure 78-19 491 Revenue Procedure 78-20 498 Revenue Procedure 78-21 499 Revenue Procedure 78-22 499 Revenue Procedure 78-23 503 Revenue Procedure 78-24 503 Revenue Procedure 78-25 505 Revenue Procedure 78-26 505 Revenue Procedure 78-27 526 Revenue Procedure 78-28 526 Revenue Procedure 78-29 526 Revenue Procedure 78-30 529 Revenue Procedure 78-31 531 Revenue Procedure 78-32 532 Revenue Procedure 78-33 532 Revenue Procedure 78-34 535 Revenue Procedure 78-35 536 Revenue Procedure 78-36 538 Revenue Procedure 78-37 540 Revenue Procedure 78-38 542

Revenue Procedure 78-39 542

Delegation Order No. 3 (Rev. 3)
(Effective July 2, 1978)

Designation to Act as
Commissioner of Internal
Revenue

1. Pursuant to authority vested in the Commissioner of Internal Revenue by Treasury Department Order No. 150-2 and Treasury Department Order No. 129 (Revision No. 2), it is ordered, that:

(a) the Deputy Commissioner shall perform the duties of Commissioner of Internal Revenue during the absence or disability of the Commissioner of Internal Revenue or when there is a vacancy in that office; and

(b) the Assistant Commissioners, in the order listed below, shall perform the duties of the Commissioner of Internal Revenue during the absence or disability of the Commissioner of Internal Revenue or a vacancy in that office and the absence or disability of the Deputy Commissioner or a vacancy in that office, except to the extent otherwise provided for specific periods of time by written designation orders which may be issued from time to time by the Commissioner:

Assistant Commissioner (Compliance)

Assistant Commissioner (Taxpayer Service and Returns Processing)

Assistant Commissioner (Planning and Research)

Assistant Commissioner (Resources Management)

Assistant Commissioner (Technical) Assistant Commissioner (Inspection)

Assistant Commissioner (Employee Plans and Exempt Organizations) Assistant Commissioner (Data Services)

2. The authority herein delegated may not be redelegated.

3. This Order supersedes Delega

(c) The authorities to issue summonses except "John Doe" monses, and to perform other functions related thereto specified in

to

26 CFR 301.7602-1(b), 301.7603-1, 301.7604-1 and 301.7605-1(a) issue summonses; to set the time and place for appearance; to serve summonses; to take testimony under oath of the person summoned; to receive and examine books, papers, records or other data produced in compliance with the summons; and to enforce summonses, are delegated to the officers and employees of the Internal Revenue Service specified in paragraphs 1(b), (c) and 1(d) of this Order and subject to the limitations stated in paragraphs 1(b), 1 (c), 1(d) and 6 of this Order.

(b) The authorities to issue summonses and to perform the other functions related thereto specified in paragraph 1(a) of this Order, are delegated to all District Directors and the following officers and employees, provided that the authority to issue a summons in which the proper name or names of the taxpayer or taxpayers is not identified because unknown or unidentifiable (hereinafter called "John Doe" summons) may be exercised only by said officers and employees and by them only after obtain ing preissuance legal review by Regional Counsel or the Chief Counsel in the case of Inspection and International Operations.

a

(1) Inspection: Regional Inspectors and Assistant Regional Inspectors (Internal Security) and Chief, Investigations Branch.

(2) District Criminal Investigation: Assistant Chief of Division; Chiefs of Branches; and Group Managers.

(3) International Operations: Assistant Director; Chiefs of Branches; Case Managers; and Group Managers.

(4) District Collection Activity: Assistant Chief of Division; Chiefs of Field Branches and Office Branches; Chiefs, Special Procedures Staffs and Groups; and Group Managers.

(5) District Examination: Chiefs of Examination Branches; Case Managers; and Group Managers.

(6) District Employee Plans and Exempt Organizations: Group Managers.

(d) The authority to issue summonses except "John Doe" summonses and to perform the other functions related thereto specified in paragraph 1(a) of this Order is delegated to the following officers and employes except that in the instance of a summons to a third party witness, the issuing officers' case manager, group manager, or any supervisory official above that level, has in advance personally au