Michael Craig v. Commissioner - Page 19




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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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