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dated April 19, 2002, for 1996, 1997, and 1998 or that he
received it. His arguments focus solely on the adequacy of the
notice. Among his arguments, petitioner claims that the notice
was not delivered by an authorized party, was not signed, and
showed no deficiency. Petitioner’s assertions, however, are
completely without merit. A notice of deficiency is validly
issued if sent by certified or registered mail to the taxpayer’s
last known address. Sec. 6212(a) and (b). There is no
requirement that the notice be specially delivered by an
authorized agent. The Commissioner is also under no obligation
to sign a statutory notice of deficiency in order for the notice
to be valid. Sec. 6212; see Commissioner v. Oswego Falls Corp.,
71 F.2d 673, 677 (2d Cir. 1934), affg. 26 B.T.A. 60 (1932);
Pendola v. Commissioner, 50 T.C. 509, 514 (1968); Stone v.
Commissioner, T.C. Memo. 1998-314. Moreover, petitioner’s
interpretation that the notice he received represented a mere
“suggestion” to pay tax is baseless given the clarity of the
language used.4 The notice was clearly labeled “Notice of
Deficiency”, stated that additional amounts were owed, and
provided a detailed listing of the deficiencies determined by
4 Sec. 7522(a) provides insight as to the content required
in a notice of deficiency by stating that “Any notice to which
this section applies shall describe the basis for, and identify
the amounts (if any) of, the tax due, interest, additional
amounts, additions to the tax, and assessable penalties included
in such notice.” However, sec. 7522(a) also provides that an
inadequate description “shall not invalidate such notice.”
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