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The notice of deficiency in question was issued by the IRS
District Director in Cincinnati, Ohio, and was signed “C. Ashley
Bullard [the IRS District Director in Cincinnati, Ohio] by BL”.
It is well settled that the Secretary or his delegate may issue
notices of deficiency. Secs. 6212(a), 7701(a)(11)(B) and
(12)(A)(i). The Secretary’s authority to issue notices of
deficiency has been delegated to District Directors and to
Directors of IRS Service Centers. See Nestor v. Commissioner,
118 T.C. 162, 165 (2002), and cases cited therein. Moreover,
there is no requirement that a notice of deficiency be signed.
Sec. 6212; Pendola v. Commissioner, 50 T.C. 509, 513-514 (1968);
Elmore v. Commissioner, T.C. Memo. 2003-123; Fox v. Commissioner,
T.C. Memo. 1993-277 n.4, affd. without published opinion 69 F.3d
543 (9th Cir. 1995).
Consistent with the foregoing, we reject petitioner’s
contention that the notice of deficiency dated February 9, 2000,
is invalid. We shall grant that part of respondent’s motion that
moves to dismiss for lack of jurisdiction as to the notice of
deficiency.
2. The Court’s Jurisdiction To Review Collection Actions
Sections 6320 and 6330 generally provide that the
Commissioner must give a taxpayer notice that a Federal tax lien
has been filed and notice that the Commissioner intends to levy
on the taxpayer’s property and offer the taxpayer an opportunity
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