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and frivolous. Following the hearing, Appeals Officer Stanton
made a determination upholding the proposed levy action after
concluding that the proposed levy action appropriately balanced
the need for efficient collection of taxes with petitioners’
concerns regarding the intrusiveness of the proposed levy action.
Sec. 6330(c)(3).
In their petition, petitioners asserted three less-than-
clear arguments in support of their contention that respondent’s
determination was erroneous:
(1) The revenue officer who executed a related notice of
lien was not delegated authority to issue a notice of lien with
respect to income taxes under section 7608(b).
(2) Petitioners were not subject to levy under section
6331(a).
(3) The Commissioner of Internal Revenue did not sign a
document the identity of which petitioners did not specify.
We address these arguments briefly below.
Authority To Issue Final Notice of Intent To Levy
Petitioners’ argument has no merit for several reasons.
First, the relevant notice is the final notice of intent to levy,
not a notice of lien that was not the subject of the notice of
determination. Second, the Secretary or his delegate (including
the Commissioner) is authorized to issue a final notice of intent
to levy. Craig v. Commissioner, 119 T.C. 252, 263 (2002) (citing
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