Clyde E. Hack and Carole J. Hack - Page 9




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          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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