-9-
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,
supra. Moreover, petitioners had an opportunity to petition this
Court to dispute the liability reflected in the notice of
deficiency but chose not to do so.
Petitioners argue further that they did not receive notice
and demand for payment. We disagree. Petitioners received
numerous notices, including the final notice, and a Form 4340.
These notices and that form satisfied requirements of section
6303(a) by informing petitioners of the amount owed and by
requesting payment. Hughes v. United States, supra at 531;
Schaper v. Commissioner, T.C. Memo. 2002-203.
For the foregoing reasons, we sustain respondent’s
determination as to the proposed levy as a permissible exercise
of discretion. We now turn to the requested penalty under
section 6673.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer’s position in such proceeding is frivolous or
groundless. We have indicated our willingness to impose such
penalties in collection review cases. Roberts v. Commissioner,
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