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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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