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notices (notices of intention to levy), as well as notices of
deficiency, receipt of which petitioner does not dispute. These
numerous notices were sufficient and met the requirements of
section 6303(a). Hansen v. United States, 7 F.3d 137, 138 (9th
Cir. 1993); Hughes v. United States, 953 F.2d 531, 536 (9th Cir.
1992); Weishan v. Commissioner, supra. “The form on which a
notice of assessment and demand for payment is made is irrelevant
as long as it provides the taxpayer with all the information
required under 26 U.S.C. � 6303(a).” Elias v. Connett, 908 F.2d
521, 525 (9th Cir. 1990).
Third, petitioner alleges that the final notice is invalid
because it was not signed by the Secretary or his delegate as
required by section 6330(a)(1). We disagree. For purposes of
section 6330(a), either the Secretary or his delegate (e.g., the
Commissioner) may issue a final notice of intent to levy. Secs.
7701(a)(11)(B) and (12)(A)(i), 7803(a)(2); see also sec.
301.6330-1(a)(1), Proced. & Admin. Regs. Here, the authority to
levy on petitioner’s property was delegated to the “Automated
Collection Branch Chiefs pursuant to Delegation Order No. 191
(Rev. 2), effective October 1, 1999. Internal Revenue Manual,
sec. 1.2.104, 102 (Nov. 24, 1999).” Wilson v. Commissioner, T.C.
Memo. 2002-242. Consistent with this delegation of authority,
the final notice on intent to levy in this case, which was
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