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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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