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GS-9 and above revenue officers and (in the case of levies on
property in the hands of third parties) GS-9 and above revenue
officers. See Delegation Order No. 191 (Rev. 2; Oct. 1, 1999)
(Rev. 3; June 11, 2001), pertaining to levies; Delegation Order
No. 196 (Rev. 4; Oct. 4, 2000), pertaining to liens. Consistent
with these delegations of authority, the Notice of Federal Tax
Lien and the notice required by section 6320, which were
initiated by Revenue Officer John Stetsko and authorized by
Acting Technical Support Group Manager Brenda McCullough, and the
final notice of intent to levy, which was issued by Revenue
Officer Stetsko, are valid. Finally, in connection with the
foregoing, we observe that there is no statutory requirement that
a final notice of intent to levy be signed. Cf. Pendola v.
Commissioner, 50 T.C. 509, 513-514 (1968) (a notice of deficiency
need not be signed in order to be valid); Fox v. Commissioner,
T.C. Memo. 1993-277 n.4 (same), affd. without published opinion
69 F.3d 543 (9th Cir. 1995); Elmore v. Commissioner, T.C. Memo.
2003-123 (same for notice of determination to proceed with levy).
Consistent with the preceding discussion, we conclude that
we lack jurisdiction in this case for the reasons set forth in
respondent’s motion to dismiss, as supplemented.
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