Brenda H. Robinson - Page 7




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          Commissioner, 95 T.C. 624, 629 (1990), affd. without published              
          opinion 956 F.2d 1168 (9th Cir. 1992).  The Commissioner may                
          redelegate that authority to his or her subordinates.  Id. at               
          629-630.  Petitioner cites no authority, and we know of none,               
          which requires the Commissioner to provide a copy to a taxpayer             
          of the delegation orders for a notice of deficiency to be valid.            
               Petitioner’s contention that she must file a return before             
          the Commissioner may determine an income tax deficiency is also             
          without merit.  Respondent may determine a deficiency for a                 
          taxpayer who has not filed a return.  Hartman v. Commissioner, 65           
          T.C. 542, 545-546 (1975).                                                   
               A taxpayer may dispute his or her underlying tax liability             
          at the section 6330 hearing only if he or she did not receive a             
          notice of deficiency for the taxes in question or did not                   
          otherwise have an opportunity to dispute the tax liability.  Sec.           
          6330(c)(2)(B).  Petitioner received notices of deficiency for               
          1993 and 1994.  Thus, petitioner was not entitled to dispute the            
          existence or amount of her tax liabilities for those years at the           
          section 6330 hearing.  Id.                                                  
          B.   Whether Respondent’s Determination To Proceed With                     
               Collection as to Petitioner’s 1993 and 1994 Tax Years Was an           
               Abuse of Discretion                                                    
               Petitioner contends that she did not receive a fair hearing            
          and that respondent’s determination to proceed with collection of           
          her 1993 and 1994 tax liabilities was an abuse of discretion                







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