Brenda H. Robinson - Page 6




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          that the notices of deficiency issued to her were not valid                 
          because they lacked a valid signature.  She contended that the              
          only persons required to pay income tax are wage earners,                   
          distillers, winemakers, brewers, tobacco dealers, and firearms              
          dealers; and that she was not one of those persons.                         
          C.   Respondent’s Notice of Determination                                   
               On February 1, 2001, respondent sent petitioner a Notice of            
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (the lien or levy determination), in which respondent           
          determined that collection from petitioner of her tax liabilities           
          for 1993 and 1994 would proceed.                                            
                                       OPINION                                        
          A.   Whether Petitioner May Dispute Her Underlying Tax                      
               Liabilities for 1993 and 1994                                          
               Petitioner contends that she was improperly precluded at the           
          section 6330(b) hearing from disputing her underlying tax                   
          liabilies for 1993 and 1994.  She bases this contention on the              
          claim that the notices of deficiency she received were invalid              
          because respondent did not provide a copy of the delegation order           
          showing that the notices were issued by persons with authority to           
          do so and because respondent may not determine an income tax                
          deficiency if she did not file a return.  Petitioner’s                      
          contentions lack merit.                                                     
               The Secretary or his or her delegate, including the                    
          Commissioner, may issue notices of deficiency.  Stamos v.                   






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