- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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