-9-
verification requirement of section 6330(c)(1). Yacksyzn v.
Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v. Commissioner,
117 T.C. 117, 120-121 (2001).
Petitioners argue further that their underlying tax
liability is incorrect. We dismiss this argument as raised
inappropriately. Given that petitioners received a notice of
deficiency for the subject year, they are not allowed to contest
either the validity or the amount of their tax liability. Sec.
6330(c)(2)(B) (individuals such as petitioners may only challenge
the existence and amount of an underlying tax liability if they
did not receive a notice of deficiency for the taxes in question
or did not otherwise have an earlier opportunity to dispute the
tax liability); see also Sego v. Commissioner, supra at 609; Goza
v. Commissioner, 114 T.C. 176 (2000).
Petitioners attempt to avoid the prohibition of section
6330(c)(2)(B) by arguing that the notice of deficiency issued to
them was invalid because, they assert, it lacked a valid
signature. We consider this argument frivolous. The Secretary
or his delegate is authorized by statute to issue notices of
deficiency, secs. 6212(a), 7701(a)(11)(B) and (12)(A)(i), and it
is well established that the director of an Internal Revenue
service center is an authorized delegate, e.g., Hughes v. United
States, 953 F.2d 531, 536 (9th Cir. 1992); Nestor v.
Commissioner, 118 T.C. 162 (2002); Weishan v. Commissioner,
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