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B. Whether Respondent’s Determination To Proceed With
Collection as to Petitioner’s 1996 Tax Year Was an Abuse of
Discretion
Petitioner contends that respondent’s determination to
proceed with collection of her 1996 tax liability was an abuse of
discretion because: (1) The notice of deficiency is invalid
because it was not signed by the Secretary; (2) the persons
sending the notices of levy and determination did not have
authority to do so; (3) respondent did not produce verification
from the Secretary that requirements of applicable law and
administrative procedure have been met; (4) respondent did not
give petitioner copies of the law which makes her liable for
income taxes; and (5) petitioner did not receive the notice and
demand required by section 6303(a). Petitioner’s contentions are
frivolous for reasons discussed next.
The Secretary, or the Secretary’s delegate including the
Commissioner, may issue notices of deficiency. Stamos v.
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.
Internal revenue laws and regulations do not require the
Appeals officer to give the taxpayer a copy of the delegation of
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