- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011